And DOES 1 Through 25, Inclusive,: Plaintiff'S First Amended Complaint

Case 8:17-cv-00644-CJC-KES Document 15 Filed 06/14/17 Page 1 of 53 Page ID #:279
1 Aperture Law Firm

Robert B. Salgado, Esq. (SBN 297391)
2 robert@aperturelaw.com
5755 Oberlin Drive, Suite 301
3 San Diego, CA 92121
Telephone: 858-223-6552
4 Fax: 858-223-6557
5 Attorney for Plaintiff: Iraj Khosroabadi
6
7
8
9
10 UNITED STATES DISTRICT COURT
Telephone (858) 223-6552 Facsimile: (858-223-6557
11 CENTRAL DISTRICT OF CALIFORNIA

12
) Case No.: 8:17-cv-00644-CJC-KES
San Diego, CA 92121
Aperture Law Firm
13 IRAJ KHOSROABADI, an Individual )

)
14 Plaintiff, ) PLAINTIFFS FIRST AMENDED
) COMPLAINT FOR:
15 vs. )
MAZGANI SOCIAL SERVICES, INC, ) 1. Intentional (Actual) Fraud (Cal.
16 )
a California Corporation, MAHVASH ) Civ. Code 1572);
17 MAZGANI, NAZANIN MAZGANI, ) 2. Violation of the Unfair Business
NEYAZ MAZGANI, MAHNAZ ) Practices (Cal. B&P 17200);
18 )
MOGHADDAM, SHOHREH ) 3. Violation of the False
19
SHARIFZADEH, and DOES 1 through ) ) Advertising Law (Cal. Bus. &
20 25, inclusive, ) Prof. Code 17500, Et Seq.);
) 4. Breach of Fiduciary Duty (20
21 Defendant(s) )
) CFR 404.1705);
22 ________________________________ ) 5. Intentional Infliction of
23 Emotional Distress;
6. Financial Elder Abuse
24 (Welf.&Inst. Code 15610.30 &
25 15657.5;
7. Racketeer Influenced and Corrupt
26
Organizations Act (RICO).
27
CTRM: 9B
28
Honorable Cormac J. Carney
PLAINTIFFS FIRST AMENDED COMPLAINT
Page 1 of 53
1
JURY TRIAL DEMANDED
2
3 EXPEDITED JURY TRIAL
REQUESTED PURSUANT TO
4 CALIFORNIA ELDER ABUSE
STATUTES
5
FILED AS CLASS ACTION
6
7
8
9
10
11
12
San Diego, CA 92121
Aperture Law Firm
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Page 2 of 53
1 INTRODUCTION
2 1. Iraj Khosroabadi (hereinafter Plaintiff), by and through his attorney of
3 record, brings this Class Action on behalf of himself, and all others similarly
4 situated, and the general public, against Defendants Mahvash Mazgani,
5 Nazanin Mazgani, Neyaz Mazgani, Mahnaz Moghaddam, Shohreh
6 Sharifzadeh, and Mazgani Social Services, a California registered corporation
7 (entity # C2509317) and DOES 1 through 25, inclusive (hereinafter,
8 collectively referred to as Defendants).
9 2. Defendant Mazgani Social Services, INC. (hereinafter MSSI) is a
10 California registered corporation with a single office at 1110 Robertson Blvd.
11 #3, Los Angeles, CA 90035, that provides aid to Americans (mostly of

Iranian descent) in applying for and receiving Social Security, Disability and
12
San Diego, CA 92121
Aperture Law Firm
13 other benefits provided by the State of California and the United States
14 Federal Government. Exhibit F.
15 3. Plaintiff alleges that Defendants illegally charge for their services above
16 and beyond the fees allowed by State and Federal Agencies and engage in
17 systematic and harassing billing practices long after their services have been
18 provided.
19 JURISDICTION AND VENUE
20 4. This Court has original jurisdiction over the causes of action arising out
21 of federal law pursuant to 28 U.S.C. 133.
22 5. For all causes of action arising in California statutory, state common
23 law, or other nonfederal claims, this Court has supplemental jurisdiction
24 pursuant to 28 U.S.C. 1367.
25 6. Venue in the Central District is appropriate as the Class Representative
26 and each Defendant reside in Los Angeles County, California.
27 THE PARTIES
28 7. Iraj Khosroabadi is a 56 year old disabled United States citizen residing
Page 3 of 53
1 in the County of Los Angeles.

2 8. Mahvash Mazgani is a natural person residing in the County of Los
3 Angeles.
4 9. Nazanin Mazgani is a natural person residing in the County of Los
5 Angeles. Nazanin Mazgani is a licensed attorney (SBN# 270258) practicing
6 in California as a sole practitioner doing business as the Law Offices of
7 Nazanin Mazgani. Nazanin uses a satellite office owned by Regus, Inc.
8 located at 11400 W. Olympic Blvd STE 200, Los Angeles, CA 90064-15841
9 for mail and correspondence, but conducts all her business out of the same
10 building as Mazgani Social Services INC. at 1110 S. Robertson Blvd., #1, Los
11 Angeles, CA 90035. Exhibit E. Suite #1 used to be occupied by Mazgani

Social Services. Exhibit F. Nazanin is Mahvashs daughter.
12
San Diego, CA 92121
Aperture Law Firm
13 10. Neyaz Mazgani is a natural person residing in the County of Los

14 Angeles. Neyaz is Mahvashs daughter.
15 11. Mahnaz Mazgani is a natural person residing in the County of Los
16 Angeles. Mahnaz is Mahvashs sister.
17 12. Shohreh Sharifzadeh is a natural person residing in the County of Los
18 Angeles. Shohreh is employed at MSSI as a secretary/support staff. Shohreh
19 manages the day-to-day operation of MSSI and maintains all the companys
20 paperwork and record keeping.
21 13. Mazgani Social Services, Inc., is a California corporation with its main
22 office located at 1110 S. Robertson Blvd., Los Angeles #3, CA 90035 in the
23 County of Los Angeles, and which has been organized under the laws of the
24 State of California. Exhibit G.
25 14. Plaintiff is ignorant of the true names and capacities of Defendants sued
26 herein as Does 1-25, inclusive and therefore sue these Defendants by such
27
1
28 See http://www.regus.com/office-space/united-states/california/los-angeles/california-west-los-angeles-executive-
tower
Page 4 of 53
1 fictitious names. Plaintiff will amend this complaint to allege their true names
2 and capacities when they have been ascertained. Each fictitiously named
3 Defendant is responsible in some manner for the occurrences herein alleged,
4 and Plaintiffs injuries as herein alleged were proximately caused by the acts
5 and/or omissions of each.
6 OVERVIEW OF ALLEGATIONS
7 15. Defendant Mahvash Mazgani (herein after Mahvash) through her
8 company Mazgani Social Services Inc. (hereinafter MSSI), provides
9 services to aid individuals in applying for Social Security benefits. Mahvash
10 holds herself out as a Social Security Representative (hereinafter
11 Representative) in California and qualifies to receive direct payments as a

non-attorney with the Social Security Administration (hereinafter SSA).
12
San Diego, CA 92121
Aperture Law Firm
13 16. Defendants have engaged in systematic and ongoing victimization of

14 mostly elderly first generation Iranians through rampant and salacious
15 violations of state and federal law. Mahvash, her two daughters Nazanin and
16 Neyaz, her Sister Mahnaz (hereinafter the Mazgani Family), and Shohreh
17 participate directly in, or in furtherance of, charging fraudulent fees to Social
18 Security claimants for the pecuniary benefit of themselves, MSSI and the Law
19 Offices of Nazanin Mazgani.2
20 17. The Mazgani Family charges their clients an initial $3,000 fee for their
21 Representative services, payable with a $500 down payment at the first
22 meeting, and through 5 additional payments after SSA benefits are received.
23 Exhibits T-7, T-10, T-11, T-25-27.
24 18. To avoid getting caught for charging their illegal fees through a potential
25 SSA audit, the Defendants have devised various money laundering techniques
26 in order to conceal the source of the money. See generally Exhibits J, P, Q
27
28 2
The Law Offices of Nazanin Mazgani lists Social Security Disability and SSI as one of the practice areas. See
[http://mazganilaw.com/practice-areas/immigration/social-security-disability-and-ssi] (as of 03/09/2017 at 22:54).
Page 5 of 53
1 & R. Defendants require that each one of their SSA claimants bring in a total
2 of six signed checks each for $500, but with the pay to lines blank. The
3 Defendants will cash the first check right away as an administrative fee
4 (See Exhibit L) and then cash each subsequent check after the claimant starts
5 receiving their benefits.
6 19. Since an SSA audit of MSSIs corporate account would reveal several
7 $500 deposits with copies of the checks (and thus the fraud), the Defendants
8 make use of the blank pay to lines by (1) depositing the checks into several
9 different accounts, some jointly held amongst the defendants and some in
10 private accounts; (2) write the checks out to Cash and take them to the
11 issuing bank to cash, and then depositing the cash into one of their many bank
accounts; or (3) writing the checks directly to a payee to satisfy a debt owed.
12
San Diego, CA 92121
Aperture Law Firm
13 20. At its core, the Mazgani Family represents itself to be a social services
14 agency through MSSI. Their advertisements are geared toward non-English
15 speakers who primarily speak and read in Farsi. As Exhibits A & B clearly
16 demonstrate, not a single operative word is written in English on either the
17 full page color advertisement or the half page black-and-white advertisement.
18 21. The Mazgani Family primarily targets that segment of the Iranian-
19 American population who qualify for, or who are in need of, social service
20 benefits provided by the state and federal governments. This population is
21 primarily comprised of disabled and elderly individuals who are a typically
22 vulnerable and often isolated segment of the population. In this case, the
23 victims are even more vulnerable and isolated due to their inherent language
24 barrier.
25 22. Obtaining benefits through social services, social security income
26 (hereinafter SSI) or social security disability (hereinafter SSD) is a
27 complicated, form-laden process that many simply cannot navigate without
28 some form of representation.
Page 6 of 53
1 23. Many of the Mazgani Familys victims are already desperate, and
2 particularly susceptible to their aggressively bullish tactics, often having to
3 borrow large sums of money from friends and family to appease the
4 Defendants.
5 24. The Defendants are able to quickly gain the trust and confidence of their
6 victims by using their common ethnicity and background to coerce victims
7 into putting their guard down. Once the Mazgani Family creates the requisite
8 deference in their victims they are better able to increase their economic gain
9 through fraud, manipulation, intimidation and fear.
10 25. Mahvash Mazgani, through MSSI, advertises her services online and in
11 print advertisements under Attorney Services even though Mahvash is not a

licensed attorney, provides no attorney services, and neither Mahvash nor
12
San Diego, CA 92121
Aperture Law Firm
13 MSSI employs a licensed attorney on staff. Exhibit A. In at least one online

14 advertisement, Mahvash actively markets herself as an attorney. Exhibit F.
15 26. By taking criminal advantage of the most vulnerable segment of an
16 already isolated population, the Mazgani Family has made millions of dollars
17 and ruined countless lives.
18
19 GENERAL FACTS COMMON TO ALL CAUSES OF ACTION
20
21 27. As many baby-boomers exit the workforce and enter retirement,
22 applications for Social Security benefits are at an all-time high. Between
23 2010 and 2012 an average of almost 3 million applications were received per
24 year, of which an average of 64% of those applications were rejected. Annual
25 Statistical Report on the Social Security Disability Insurance Program, Pg.
26 147-148 (2015).
27 28. In response to the increase in applications, the SSA passed the Social
28 Security Disability Applicants Access to Professional Representation Act of
Page 7 of 53
1 2010 (hereinafter the SSD Act) that permanently extends fee withholding to
2 all eligible non-attorney representatives. The purpose of this act is to allow
3 an eligible non-attorney to represent the applicant should their application be
4 rejected.
5 29. MSSI is a closely-held corporation with Mahvash and her two daughters
6 listed as the only Corporate Officers and Directors. Exhibit G-1. Mahvash is
7 the CEO, Nazanin is the Secretary and Neyaz is the CFO. Id. They were
8 incorporated in California on December 21, 2005. Id.
9 30. The Mazgani Family are well-educated and sophisticated. Mahvash
10 Mazgani is an urbane, British educated businesswoman; Nazanin Mazgani is
11 a seasoned attorney licensed to practice law in the State of California, (SBN:

270258); and Neyaz Mazgani has spent the last 18-years of her life (post-
12
San Diego, CA 92121
Aperture Law Firm
13 secondary school) in academia and is currently working on a doctorate in law.

14 Exhibit A-2 touts Mahvashs 23 years of Social Security experience.
15 31. Mahvash, Nazanin, Mahnaz, Shohreh, Neyaz, and MSSI are all distinct
16 sprockets playing a role in the Mazgani Family Fraud. Mahvash, Neyaz and
17 Nazanin all work in the same office at 1110 S. Robertson BLVD in Los
18 Angeles. See Exhibits A&E. Neyaz admits working for MSSI until 2009.
19 Exhibit M-2 4. On April 4, 2017 a picketer was assaulted outside the MSSI
20 office at 1110 S. Robertson by Mahvash and Neyaz who were both working
21 there at the time.3 The Plaintiff in that case claims that Mahvash, Neyaz and
22 Nazanin were all present during the altercation.4
23 32. In advertisements for MSSI, Mahvash uses different Suite #s at the same
24 address. Compare Exhibit A with Exhibit F, and Exhibit F with Exhibit E-
25 1&E-2. This is because Mahvash and MSSI rent more than one suite at 1110
26
3
27 Complaint at 2-4, Iglesias v. Mazgani Social Services, INC et al, No. BC657191, (Superior Court, Los Angeles
filed April 10, 2017).
4
28 Iglesias Dec.15-16, Iglesias v. Mazgani Social Services, INC et al, No. BC657191, (Superior Court, Los
Angeles filed April 10, 2017).
Page 8 of 53
1 Robertson Blvd., and the entire Mazgani Family works there.

2 33. Both Neyaz and Mahvash claim that Neyaz does not currently perform
3 any work or engage in any formal or informal functions for MSSI. Exhibit
4 L-1 5, Exhibit M 3&4. Neyaz also claims that she has not worked at
5 MSSI since 2009.
6 A. Plaintiff Iraj Khosroabadis Verfied Allegations Common to all Causes
7 of Action
8 34. In mid-February, Iraj began looking into applying for disability benefits
9 from the SSA because he was no longer able to work due to back pain. Iraj
10 made contact with the SSA who sent him a letter describing what he would
11 have to do to apply for disability benefits. While at a restaurant, a friend

suggested that Iraj get legal representation to help him with the application
12
San Diego, CA 92121
Aperture Law Firm
13 with the warning that if he tried to do it alone, his claim would be rejected.
14 35. Iraj looked online for attorneys who speak Farsi. Iraj found a few
15 different attorneys online through Connect Iranian American (Exhibit F),
16 including Mahvash Mazgani. Since Iraj is not very good with technology, he
17 decided to look in the attorney section of the 2016 edition of The Iranian
18 Pocket Directory Yellow Pages (Exhibit C) where he found two ads from
19 Mazgani Social Services in the Attorney Services Bureau section. Exhibits
20 A-2&A-3. He recognized Mahvash from his search online.
21 36. Iraj made contact with Mahvash Mazgani to inquire about SSA benefits
22 on February 23, 2017. Mahvash informed Iraj that since 2005 they have
23 helped thousands of people obtain social security benefits and that the
24 Defendants mainly represent Iranian-Americans, particularly elderly and
25 disabled Iranian Americans before the Social Security Administration. He
26 was instructed by Mahvash Mazgani to appear at her office at 11:00 a.m. on
27 March 1, 2017 and to bring with him a money order for $500 as a down
28 payment on the $3000 fee. He was also told to bring his citizenship
Page 9 of 53
1 documents and any medical records he could get that document his disability.
2 See Exhibits H, I, and J.
3 37. On February 28, 2017, Plaintiff obtained a Money Order from Western
4 Union bearing number *******6814 and noted in Farsi on the check that it be
5 payable to Mazgani and that it was a payment for SSA related work to receive
6 SSI and SSD. See Exhibits H&I. Iraj borrowed the $500 from a family
7 member.
8 38. On March 1, 2017, Plaintiff appeared at the office of Mazgani Social
9 Services, Inc., located at 1110 South Robertson Blvd, Los Angeles, CA
10 90035. Iraj believed that the meeting was just a quick formality for him to
11 drop off all of his paperwork and to sign a contract. Iraj was not able to get
all of his citizenship paperwork because he had just recently separated from
12
San Diego, CA 92121
Aperture Law Firm
13 his wife and she had all of his documents. His wife was afraid that Iraj would
14 go back to Iran and marry another woman, so she refused to give him his
15 citizenship papers and his passport, though he did manage to get a copy of his
16 citizenship papers.
17 39. Knowing that he did not have all the paperwork Mahvash would need to
18 process his SSD application, and because he did not bring anything to write
19 with, Iraj decided to record his conversation with Mahvash so that he could
20 remind himself of everything he had to get for Mahvash after he left. Iraj
21 used a recording application on his iPhone. There are three different audio
22 recordings of the interview, each in succeeding order. Iraj turned his recorder
23 on after he entered the MSSI office. Exhibit T-1. After a brief conversation
24 with Shohreh about the paperwork he brought in, he turned off the recorder
25 thinking that he might have to wait for Mahvash to see him. Mahvash was in
26 her office with the door closed.
27 40. Mahvash eventually came out of her office and asked Iraj to come in.
28 Mahvash sat at her desk and Iraj sat in a chair. Mahvash did not close the
Page 10 of 53
1 door to her office during their interview. After he sat down Iraj took his
2 phone out and started recording again, then put his phone back in his pocket.
3 Exhibit T-6. Shohreh was giving Mahvash his paperwork and they had a
4 brief conversation. Mahvash reviewed his paperwork while Iraj waited.
5 Mahvash told Iraj what the fee was for applying for SSD. Exhibit T-7.
6 41. Iraj asks if Mahvash can waive her fee, but she says Definitely not!
7 Exhibit T-9. While she is having Iraj sign the contract in various places, she
8 goes over the fee again, as if it was a term in the contract that he is signing.
9 Id. Mahvash foreshadows her future threats by answering Irajs questions
10 about the chances of him being accepted, she states I cant give you 100%
11 guarantee, because I am not the decision maker. If I were the one who makes
the decision, I would hand it over to you after you give me the $3,000 fee.
12
San Diego, CA 92121
Aperture Law Firm
13 (bold and italics added). Id.

14 42. Iraj does not speak English very well and is even worse at reading in
15 English. Iraj was never provided with a copy of this contract and does not
16 know the contents of the contract that he signed because it was all in English.
17 Mahvash and Shohreh quickly had Iraj sign the documents without explaining
18 their contents.
19 43. Iraj gave Mahvash the $500 money order and asked her if she wanted
20 him to fill it out. Mahvash replied we will complete it. Shohreh came in
21 later and took the money order and the signed contract. Exhibit T-11.
22 44. At Exhibits T-12-18 Mahvash begins to ask Iraj a barrage of personal
23 questions about his family, his wife, his kids, his sister, his nephews, and
24 pretty much anyone else she can get information about. Iraj went out to his
25 van to get more documents, and then brought them back to Mahvashs office
26 to go through. He turned off the recording while going through the
27 documents in Mahvashs office.
28 45. After reviewing some of his paperwork, Mahvash comes back into the
Page 11 of 53
1 office to review as well. After she sits down in front of him, Iraj pulls out his
2 phone and begins recording again. They talk mostly about his medical
3 records and his disabilities. Mahvash again goes over her $3,000 fee and the
4 requirements for the five $500 checks. Exhibit T-25. Iraj asks what will
5 happen to the $500 if he is rejected and Mahvash responds You say bye bye
6 to it. Exhibit T-27. Iraj clarifies with Mahvash that she needs five signed
7 and undated checks with your names on them. Mahvash responds Yes,
8 with my name on them. Each $500. Exhibit T-28. Iraj then leaves the
9 office and turns off the recording.
10 46. At that March 1, 2017 meeting, Plaintiff personally met with Mahvash
11 Mazgani and Shohreh Sharifzadeh. Mahvash conducted the meeting in her

office with the office door open so that Shohreh, who was visible through the
12
San Diego, CA 92121
Aperture Law Firm
13 door in the lobby, could listen in, take notes, and answer questions when
14 asked. Other people in the lobby could easily hear the conversation between
15 Iraj and Mahvash, and Mahvash stopped several times to answer the phone
16 and talk to other clients about their claims in front of Iraj. Iraj remembers that
17 at least one person was waiting in the lobby when he first arrived. During the
18 meeting, Iraj saw people walking in and out of the office while he was
19 speaking to Mahvash. At various times during the meeting, Shohreh would
20 interject to confirm that Mahvash had the correct paperwork. Shohreh would
21 also bring Mahvash additional paperwork to have Iraj fill out. The purpose of
22 the meeting was for Iraj to bring Mahvash all the paperwork she needed and
23 to sign the contract.
24 47. Iraj remembers that Mahvash seemed a little irritated by Irajs questions
25 about the $3,000 fee and began to ask Iraj several probing questions about his
26 family. She wanted to know everything about Iraj: his ex-wives (and their
27 birthdates); the names, addresses and birthdates of his current wife; the names
28 addresses and birthdates of his children from both inside and outside his
Page 12 of 53
1 current marriage; the name address and birthdate of his sister; the name
2 address and birthdate of his sisters husband; the names addresses and
3 birthdates of his sisters children; information on everyone who lived at his
4 sisters house, Irajs relationship to them, and how much he pays in rent; and
5 even wanted information about Irajs friend who suggested he get help in
6 applying for SSA benefits. Exhibit T12-18. Iraj provided most of the
7 requested information, but felt very uncomfortable about providing Mahvash
8 with information about his children and his nephews, who have absolutely
9 nothing to do with his SSD claim.
10 48. Iraj asked Mahvash if it was absolutely necessary that she know the
11 names, addresses and birthdates of his children and nephews (for his SSA
claim), to which Mahvash insisted it was. Exhibit T-12.
12
San Diego, CA 92121
Aperture Law Firm
13 49. The money order would later be cashed by Mahvashs sister Mahnaz
14 Moghaddam. Exhibits H&I. The bottom left side of the money order
15 contains Irajs hand written notes. The first note is written in Farsi and says
16 Ms. Mazgani and the second note in English is SSi. The name written in
17 the Pay To line is M. Moghaddam in distinct handwriting from Iraj.
18 There is no purchaser signature on the money order, and the money order was
19 not endorsed. The reverse side of the money order has no bank stamp which
20 means that it was cashed. Since there was no purchaser signature, there was
21 no need to endorse the money order, and it could easily be cashed at any
22 Western Union with just the pay to line filled out. The money order was
23 cashed on April 22, 2017.5
24 50. After this meeting, Iraj went to his bank and was given several checks to
25 draw on his account. Iraj provided 5 signed blank checks for $500 with the
26
27
5
Dialing 1-800-999-9660 and entering check# 17546856814 and the amount as 50000 reveals the following
28 message: A money order customer request has been received. The money order has paid. Please allow fifteen
business days from April 22, 2017 to receive a photo copy.
Page 13 of 53
1 pay to lines blank to Mahvash Mazgani.

2 51. In the days after paying the initial $500 fee, Iraj felt uncomfortable
3 providing Mahvash with the blank checks and again asked her if they were
4 necessary. Mahvash told Iraj that this was their standard fee for Social
5 Security applications. Mahvash warned Iraj that if he failed to pay the rest of
6 the $3,000 fee that he would forfeit his SSA benefits and lose his $500.
7 52. Iraj went to his bank and had them print out several checks drawn on his
8 checking account. When Iraj went back to Mahvashs office he delivered the
9 checks to Shohreh who took them. The checks were for $500 each and were
10 signed. Iraj put Ms Mazgani ssi in the memo of each check. The checks
11 had the pay to lines and the date lines blank.

53. Iraj sought out legal advice and a complaint was filed against Mahvash,
12
San Diego, CA 92121
Aperture Law Firm
13 Neyaz, Nazanin and MSSI on March 13, 2017. After the complaint was filed
14 Iraj started to receive more frequent and harassing phone calls from Mahvash.
15 54. On March 15, 2017 Mr. Khosroabadi received a call from Mahvash
16 saying that she needed to talk to him, to which Mr. Khosroabadi stated This
17 is not Iraj and hung up. See Dec. of Iraj Dkt 9-2 7-8. Later that day he
18 received a call from Shohreh who insisted that Iraj come into the office to talk
19 about the situation and not let it blow up. Id. Iraj told Shohreh to call my
20 lawyer and hung up the phone. He received several more calls from Shohreh
21 that day but he did not answer them.
22 55. On March 20, 2017 Iraj started receiving phone calls from various
23 restricted numbers that would hang up when he answered. On March 22,
24 2017 an unidentified man came to Mr. Khosroabadis post office box and
25 asked the postal worker if he knew Iraj, where Iraj lived, and when he
26 typically came to collect his mail. The man was intimidating, and made the
27 postal worker nervous. The postal worker told the man that he was not
28 allowed to disclose any personal information about their customers. Iraj
Page 14 of 53
1 asked the postal worker if he would be willing to sign a statement describing

2 these events, but he refused out of fear for his own personal safety. The
3 attorney of record for the Plaintiff has the postal workers name and contact
4 information and reserves the right to subpoena the postal workers testimony
5 at a TRO hearing, deposition, and/or trial.
6 56. On March 27, 2017, Iraj was leaving his house, and a large man was
7 trying to come into his secured building. Iraj asked him what he was doing
8 there, as no one can gain entry without being admitted by a tenant. The man
9 said that he was looking for Iraj, and Iraj lied and told him that he did not
10 know Iraj. The man engaged Iraj in some light conversation during which
11 Iraj tried to covertly take a picture of the man with his phone, but was not able
to get a clear shot of his face. Exhibit U. The man eventually told Iraj that
12
San Diego, CA 92121
Aperture Law Firm
13 he needed to go to Unit 105, and Iraj accidently told him that unit 105 was
14 his. The man said: You must be Iraj. Iraj asked why the man was asking.
15 The man said people that you have sued arent happy. At that point Iraj
16 noticed a bulge underneath the mans jacket. When Iraj saw him begin to
17 reach for that bulge he panicked and ran out of the building into the parking
18 lot. Iraj got into his car and watched the man drive out of the apartment
19 complex. Iraj followed him into the Jons Marketplace at 18135 Sherman
20 Way, Reseda, CA and took a picture of his license plate.6 After driving by the
21 mans car, the man pulled out of the parking spot and started following Iraj.
22 Iraj called his attorney of record who advised him to drive to the police
23 station. The man did not follow Iraj into the police station parking lot. We
24 are currently tracking this man down from the picture of his license plate.
25 57. On March 30, 2017 Mahvash went to Irajs sisters house and threatened
26 to file false claims against Irajs nephew with the California Bar Association
27
28
6
We are currently tracking down the registered owner of the vehicle.
Page 15 of 53
1 if he did not drop the class action. Dec. of Iraj 12. When Irajs sister asked
2 Mahvash if she was threatening her Mahvash replied I will kill for my
3 children. Despite multiple attempts, Irajs sister refuses to provide a
4 declaration. We reserve the right to subpoena her testimony at a future
5 hearing or at trial.
6 58. On April 3, 2017 Iraj received two calls from Mahvash. The first call
7 was at 11:19a.m. Exhibit K-2. Iraj answered the phone and Mahvash began
8 yelling at him right away. He told her to contact his lawyer and hung up. At
9 11:21a.m. Mahvash called Iraj back and again started yelling at him. Iraj
10 again told her to stop calling him and to contact his lawyer. Exhibit K-1.
11 Later that same day Iraj received a call on his cell phone while he was driving
with his wife. His wife answered the cell phone and turned white. She was
12
San Diego, CA 92121
Aperture Law Firm
13 so scared that she started to have a panic attack, so Iraj took her to the
14 emergency room where she obtained treatment. Exhibit V-1 is a picture
15 taken of Irajs wife at the ER. The next day Iraj took his wife to San
16 Fernando Valley Community Mental Health Center, Inc. for follow-up
17 treatment. Id. at V-2.7
18 59. On April 5, 2017 Mr. Khosroabadi received a call from an unknown
19 number; when he answered the phone a man on the other end said Is this
20 Iraj? Iraj replied yes. The man said Ill be watching you, you
21 motherfucker, were watching you. Exhibit K-3 is a screenshot taken from
22 Irajs cell phone of the call.
23 60. Even after filing a Temporary Restraining Order on April 7, 2017
24 (considered moot after removal) Mahvash still continued to harass Iraj. On
25 April 17, 2017 Mahvash called Iraj twice, Iraj did not answer the first call, but
26 answered the second. Iraj told Mahvash that he did not want to talk to her,
27
28
7
As of the date of this complaint we have not yet received medical records.
Page 16 of 53
1 and hung up. Exhibts K-4&K-5. Before dealing with the Mazgani Family,
2 Iraj never received any threatening phone calls.
3 61. Iraj continues to receive phone calls from restricted numbers; most of the
4 time he does not answer, but when he does they just hang up.
5 B. Additional Allegations Common to All Causes of Action
6 62. The Law Offices of Nazanin Mazgani provides legal assistance to
7 MSSIs clients in obtaining benefits in her independent capacity as a licensed
8 attorney in the State of California, knowing that Defendants MSSI, Mahvash
9 Mazgani, Neyaz Mazgani and DOES 1 through 10 had already collected a fee
10 from (1) the SSA, (2) the client, and/or (3) were in the process of collecting
11 said fees. See Exhibits E, G,&S.

63. As discussed hereinabove, Nazanin maintains a satellite office, but
12
San Diego, CA 92121
Aperture Law Firm
13 conducts all of her business out of the 1110 S. Robertson Blvd. address.
14 Mahvash and MSSI refer their clients to Nazanin when they have been denied
15 through the SSA application process, and are facing an appeal in front of an
16 Administrative Law Judge. Mahvash and Nazanin state that they have never
17 simultaneously represented a client. (Exhibit L 5, Exhibit N 5). This is
18 because attorneys licensed in California are forbidden from making financial
19 arrangements with Non-Lawyers. California Rules of Professional Conduct
20 Rule 1-320. Nazanin advertises the exact same Social Security Disability
21 related services as Mahvash, including Initial Filings. Exhibits B&D.
22 Nazanin also states that the vast majority of her SS practice involves advising
23 clients who were denied SSA benefits and seek to have the decision reversed,
24 despite advertising initial filings on her website. Id. Exhibit N 5.
25 64. When an MSSI client is referred to Nazanin, a new agreement is drafted
26 between the attorney and the client. If a claimant is successful on appeal in
27 front of an Administrative Law Judge, then the claimant will collect their SSA
28 benefits. A social security Representative cannot get paid until the
Page 17 of 53
1 beneficiary receives an award of SSA benefits. Mahvash then sends in her

2 fee request to the SSA, and begins to cash the $500 checks that she received
3 from the client. As such, the agreement between MSSI and the claimant is
4 still valid and enforceable, even if the claimant is referred to Nazanin for legal
5 services. Mahvash collects the rest of the $3,000 if Nazanin successfully
6 wins on appeal and the claimant receives SSA benefits.
7 65. The Law Offices of Nazanin Mazgani derived pecuniary gain through
8 their business dealings with MSSI, Mahvash Mazgani, Neyaz Mazgani, and
9 DOES 1 through 10 by benefitting from, and acting in furtherance of, the
10 fraudulent business practices of MSSI and their agents.
11 C. Defendants Collected Illegal Fees

66. 20 CFR 404.1705 authorizes an individual to appoint a representative
12
San Diego, CA 92121
Aperture Law Firm
13 in dealings with the SSA. This individual may either be (1) a licensed
14 attorney that is not otherwise disqualified or suspended from acting as a
15 representative and is not otherwise prohibited by law from acting as a
16 representative, or (2) a non-attorney generally known to have a good
17 character and reputation who is capable of providing valuable help with the
18 claim and who is not disqualified, prohibited or suspended from acting as a
19 representative.
20 67. 20 CFR 404.1720 restricts the mode and the amount of compensation
21 that a representative like the Mazgani Family can receive for representing an
22 applicant before the SSA.
23 68. The language of CFR 404.1720 is unambiguous, stating that [a]
24 representative may charge and receive a fee for his or her services as a
25 representative only as provided in paragraph (b) of this section.
26 69. Language of CFR 404.1720 (b) is also unambiguous stating that when
27 charging and receiving a fee related to your claim, (1) [t]he representative
28 must file a written request with us before he or she may charge or receive a
Page 18 of 53
1 fee for his or her services. (2) We decide the amount of the fee, if any, a
2 representative may charge or receive. (3) Subject to paragraph (e) of this
3 section, a representative must not charge or receive any fee unless we have
4 authorized it, and a representative must not charge or receive any fee that is
5 more than the amount we authorize. (4) If your representative is an attorney
6 or an eligible non-attorney, and you are entitled to past-due benefits, we will
7 pay the authorized fee, or a part of the authorized fee, directly to the attorney
8 or eligible non-attorney out of the past-due benefits, subject to the limitations
9 described in 404.1730(b)(1). If the representative is a non-attorney who is
10 ineligible to receive direct fee payment, we assume no responsibility for the
11 payment of any fee that we have authorized.

70. The Mazgani Family has uniformly collected an unlawful fee from
12
San Diego, CA 92121
Aperture Law Firm
13 thousands of their clients who hired MSSI to represent them in their SSA
14 claims since at least 2009, and potentially sooner. See generally Exhibits P,
15 Q, R&T.
16 71. The Mazgani Family accomplishes its vile intent by requesting their
17 $3,000 fee in addition to what the SSA will authorize as its payment pursuant
18 to CFR 404.1720 et seq. The Mazgani Family makes a little on the front-
19 end, and then makes a little on the back-end, all at the expense of their elderly
20 and disabled clients and taxpayers.
21 72. The Defendants have argued that the initial fees they charge their clients
22 are allowed by the SSA as an out-of-pocket expense (hereinafter OPE).
23 Exhibit O-3&O-7. The SSA states that Representatives are allowed to
24 charge a claimant an upfront fee for actual or expected OPEs without first
25 receiving the SSAs authorization. Id. These OPEs may be accepted in
26 advance by the Representative as long as he or she holds it in a trust or
27 escrow account. Exhibit O-7.
28 73. The SSA states that Out-of-pocket expenses are expenses incurred by
Page 19 of 53
1 the representative for which the representative has been paid or expects to be
2 paid. Out-of-pocket expenses include, but are not limited to, the cost of
3 obtaining copies of doctor or hospital reports, birth or death certificates,
4 postage, and photocopying. They do not include paralegal or secretarial
5 services, in-house experts, review of fees, or any share of the representative's
6 overhead or utility costs. GN 03920.010A.48
7 74. The SSA provides additional clarification stating that We do not
8 authorize out-of-pocket expenses (see examples of out-of-pocket expenses
9 in GN 03920.010A.4). These expenses are a matter for the representative and
10 claimant to settle. However, we will question out-of-pocket expenses if it
11 appears that the representative is attempting to circumvent our fee

authorization process by designating his or her services as out-of-pocket
12
San Diego, CA 92121
Aperture Law Firm
13 expenses or if the alleged out-of-pocket expenses appear unreasonable. GN

14 03920.010C.9
15 75. Mahvash states under penalty of perjury that she charged Iraj $500 for
16 administrative costs for her work as his SSA representative. Exhibit L 8.
17 Mahvash also states under penalty of perjury that when a client is not
18 approved for benefits, MSSI only charges them $500 for out-of-pocket
19 administrative costs. Id. at 6.
20 76. The recordings taken of Mahvashs interview with Iraj show that
21 Mahvash is lying. Exhibits T-9, T-11, T-25&T-27-28.
22 77. Irajs money order, which was provided to Mahvash un-signed and with
23 the pay to line blank, was given to Mahvashs sister Mahnaz who did not
24 deposit the check into a corporate account, trust account or escrow account.
25 Exhibit I. Instead, Mahnaz cashed the check, either for her own pecuniary
26 gain or to return to Mahvash in furtherance of the Mazgani Family Fraud.
27
8
28 http://policy.ssa.gov/poms.nsf/lnx/0203920010
9
Id.
Page 20 of 53
1 78. Blacks Law Dictionary defines Administrative Expenses as

2 OVERHEAD. Overhead is defined as: Business expenses (such as rent,
3 utilities, or support-staff salaries) that cannot be allocated to a particular
4 product or services; fixed or ordinary operating costs. Also termed
5 administrative expense; office expense. Blacks Law Dictionary 51, 1213
6 (9th ed. 2009).
7 79. MSSI requests fees directly from their clients before submitting any fee
8 requests to the SSA by charging $500 or more at the initial meeting with a
9 client, and then by demanding subsequent fees from their clients in an
10 aggregate amount of $3,000 or more (usually 6-checks in the amount of $500
11 each). Defendants insist that their clients either pay in cash or with a check or
money order with the Pay to the Order of line on the check left blank.
12
San Diego, CA 92121
Aperture Law Firm
13 D. Mahvash and Neyaz Laundered Money

14 80. Exhibit P is a selection of credit card statements from a Wells Fargo
15 credit card (Acct #: 5074) in Mahvashs name. Plaintiff alleges that the
16 Defendants engage in money laundering by cashing $500 checks illegally
17 obtained from MSSI clients for Representative services. This credit card is
18 used as overdraft protection for other accounts belonging to Neyaz. Exhibits
19 P-1-4 shows; (1) a $500 cash payment on 4/15/2010 in the branch; (2) a $500
20 cash payment made on 6/02/2010; (3) a $2000 payment made on 7/30/2010;
21 and (4) a $500 cash payment made on 8/25/2010 in the branch.
22 81. Exhibit Q shows several combined statements from Mahvashs Wells
23 Fargo checking account (Acct#: *****73152 (hereinafter 3152)) and her
24 Wells Fargo Money Market savings account (Acct#: ******1231 (hereinafter
25 1231)). Exhibits Q-1&Q-2 is the first statement after the account was
26 opened in August, 2012. The first deposit was for $16,938.7, and then about
27 ten days later she writes several checks on the account. At least one check
28 was cashed. The checks continue from Acct: #3152 into the next month from
Page 21 of 53
1 Exhibits Q-5&Q-6. From the money market savings (1231) she deposits
2 $18,000 into a Barclays Bank account. Exhibit Q-10&Q-11 is a statement
3 from December 2012 to January 2013 that shows a $700 withdrawal and a
4 $4000 cashed check. Exhibits Q-14&15 show a $5000 in branch transfer
5 from Acct: 1231 to Acct: 3152, and then a few days later, several more $1000
6 checks are drawn on the account, even overdraftting the account by
7 $1,173.61, of which is covered by Acct: 1231. At Exhibit Q-18 Neyaz is
8 added to the account (February, 2013 March, 2013 statement). The account
9 is overdrafted again and then two transfers to into the account, one for $2,500
10 from Savings Acct#: 1268 and another for $2,500 transfer from Acct#:1231.
11 Those new balances are then almost immediately written out in several
checks, at least one of which was cashed. The next statement from March-
12
San Diego, CA 92121
Aperture Law Firm
13 April, 2013 Shows another overdraft and two transfers from Acct#:1231 to
14 Acct#:3152. The transfers are for $1,200 and $1,300. Exhibits Q-22-24.
15 Acct#: 3152 is zeroed out soon thereafter and closed as is Acct#:1231.
16 Creating short-term accounts for the purpose of distributing large sums of
17 money is a common tactic amongst money launderers. The transfers for
18 $2,500 represent their $3,000 fee minus the $500 initial payment. Other
19 deposits and cashed checks will go to various conspirators to cash or deposit,
20 but the money ends up back at MSSI.
21 82. Exhibit R is a series of statements from Neyazs personal checking
22 account also at Wells Fargo. This is a very large exhibit (264 pages) but the
23 exhibits provide a very clear window into the Mazgani Family Fraud. The
24 statements go from January, 2010 to January, 2014. Not every month is
25 included in these exhibits, though almost every statement shows some
26 fraudulent activity. What we are looking for are cash deposits, large deposits
27 that are then redistributed in checks, large payments on credit cards and one-
28 time or multiple personal checks cashed or deposited in the account from
Page 22 of 53
1 potential victims.
2 83. R-1-10 starts right away with a $400 cash deposit and two personal
3 checks for $300 from likely SS claimants. We believe that discovery will
4 show that many of the personal checks deposited by Neyaz were from clients
5 of MSSI. Lastly, there is a $500 cash deposit. Exhibits R-1-10.
6 84. R11-21 show a $500 payment to a credit card at US Bank, a $400 cash
7 deposit and a $500 cash deposit. There is one personal check for $90 made
8 out to Neyaz Mazgani.
9 85. R22-28 shows two separate $500 deposits (one cash and another by
10 personal check), and one transfer from another checking account (#3494) for
11 $350. Immediately after the first $500 cash deposit two payments are made
on two different credit cards, one US Bank and another Citicard, both for
12
San Diego, CA 92121
Aperture Law Firm
13 $500. She also makes a $500 payment on an American Express card.

14 Despite depositing $500 cash on 5/24/10, she is back at the bank on 5/27/10
15 to take $180 in cash out. The personal check for $500 deposited in Neyazs
16 account is made out to cash.
17 86. This goes on and on, $500 deposits come in, and go out. Almost every
18 personal check is different. Here are some highlights: R-42 personal check
19 made out to cash; R-44 more $500 cash deposits and credit card payments; R-
20 60 $1000 cash deposit and more $500 payments on credit cards, including a
21 personal check for $100 made out to Mazgani at R-68.
22 87. Also of note at R-60 is that there are two $500 payments to two different
23 US Bank credit cards. The first payment to Acct Number:
24 *****************6874 is Mahvashs credit card, not Neyaz.
25 88. At R-89-92 there are more cash deposits, one for $2000 and one for
26 $1000. There are also more $500 checks written to credit cards.
27 89. R-113-114 shows more $500 deposits, some cash and some checks.
28 Another $500 payment on a credit card, a $50 dollar personal check deposited
Page 23 of 53
1 in Neyazs acocunt at R-118, and a $500 check made out to Mrs. Mazgani
2 at R-119. R-126 is a $500 personal check made out to cash.
3 90. R-130-133 have more $500 deposits, but no payments to the credit
4 cards. The checks deposited give us a little more insight: a $500 business
5 check made out to Mazgani at R-136; a personal check for $300 made out
6 to Neyaz Mazgani (R-139); and a $100 personal check to N. Mazgani at R-
7 140 that has some Farsi written in the memo line that translates to: for SSI
8 Ms. Mazgani. At R-149-150 there is a $130 cash deposit into Neyaz
9 account, and then a check written out for $130 just a few days later. Another
10 $130 cash deposit is made toward the end of the statement. This kind of
11 activity is an indication of money laundering.

91. R-157-158 has another odd coincidence. On March 12, 2012 Neyaz
12
San Diego, CA 92121
Aperture Law Firm
13 writes a personal check for $130, and then two days later receives a check
14 from Nazanin drawn on her law firm account for $130. R-157&R-162. Then
15 on March 16 Neyaz writes another personal check for $130, and then ten days
16 later gets a transfer from checking acct: 3494 for $130. R-166 is a personal
17 check for $230 made out to Neyaz. The memo line says Mimi. Id.
18 92. The very next statement contains another cash deposit for $130 and
19 another personal check for $130. R-168. A $700 cash deposit is made, and
20 then a $700 payment on the Citicard was made. Id. R-173-174. A deposit of
21 $1010.51 was made on May 1, which is really $240 in cash, a $500 personal
22 check made out to Cash, and a State of California check. R-169& R-179-
23 182.
24 93. R-186-187 contains more suspect transactions: $500 payment to Amex,
25 $1000 personal check on the same day as a $1010 cash deposit (see also R-
26 192-193), $700 payment to Discover, and $300 payment on Neiman-Marcus
27 Card; a $751 cash deposit (R-190); a personal check for $100 to Neyaz
28 Mazgani; and a $500 personal check made out to cash. The payment to
Page 24 of 53
1 the Neiman-Marcus card (acct: ***8834) is Mahvashs credit line, not Neyaz.
2 94. R-203-205 has more suspect transactions: $500 payment to Discover;
3 $800 personal check to Mazgani; a $140 cash withdrawal and the next day
4 a $120 cash deposit; $500 payment to Amex; a $600 cash withdrawal; and a
5 $100 personal check made out to M. Mazgani (deposited by Neyaz).
6 95. R-217-220 is also writhe with suspect transactions: $400 cash deposit;
7 $301 check drafted on the account; a $500 cash deposit; $447.37 payment to
8 Discover; $1000 transfer from savings account #4796; a $700 cash deposit
9 from Riverside, CA; several cash deposits from September 4 September 9;
10 and a $50 personal check from Social Services Specialist Inc. (R-227).
11 96. R-233-236 contains: $500 cash deposit; a $300 transfer from savings
#4796, and then a $300 transfer back to the savings account; a $300 cash
12
San Diego, CA 92121
Aperture Law Firm
13 deposit; and no credit card payments.

14 97. R-244-247 contains: transfer from checking #3494 for $150; a transfer
15 of $1500 from Family Trust Savings #6505 with a $1500 check written on the
16 account made the same day; a $1500 transfer from Family Trust savings with
17 a $1500 personal check drafted on the account just 3 days later; and a $200
18 cash deposit.
19 98. R-252-255 contains: 2 $200 cash deposits, with $80 cash withdrawal the
20 day before the second $200 cash deposit, and a $200 cash withdrawal the day
21 after the second cash deposit; various other cash deposits; a $1000 check
22 drawn on the account with a $1000 transfer 3 days later from Family Trust; a
23 withdrawal of $100 cash on 12/26; and a cash deposit of $100 on 12/27 at the
24 ATM on W Pico Blvd, then a $100 cash withdrawal the same day from an
25 ATM on N. Vermont Ave.
26 99. Exhibit W contains other checks that were either deposited into or
27 cashed from Neyazs checking account ending in 8148. Exhibit W-1 is the
28 second personal check deposited by Neyaz from this individual. Of particular
Page 25 of 53
1 importance is the existence of the same Farsi characters that translate to For
2 SSI Ms. Mazgani in the memo line of the check, and the fact that the pay
3 to line is written in different handwriting from the other check in Exhibit R-
4 140. Exhibit W-1 appears to be written by someone else, but the pay to
5 line in Exhibit R-140 clearly has the same handwriting as Neyaz,
6 demonstrating that this check was delivered with a blank pay to line.
7 100. Exhibit W-2 is written to Mazgani with the word Mom written in
8 the memo line. This personal check suggests that it was drafted for the
9 benefit of that persons mother, a likely client of MSSI. Exhibit W-3 is
10 another check written to cash and Exhibit W-4 was written to the order of
11 M. Mazgani and not Neyaz, yet it was deposited in Neyazs account.

101. Exhibit W-5 is another check written to Mazgani and W-6 contains
12
San Diego, CA 92121
Aperture Law Firm
13 Neyazs account number in the memo line and the letters BB.
14 102. Exhibit W-8 still has a blank pay to line, yet Neyaz deposited the
15 check anyway while Exhibit W-9 is made out to Mrs. Mazghani when
16 Neyaz isnt married. W-10 is made out to cash and W-11 is made out to
17 Mazgani but contains S*S on the notes line, likely the middle character
18 was scratched out and is supposed to stand for Social Security.
19 103. Exhibit W-12 is a check made out to Mazgani in the same
20 handwriting as Neyaz, and Exhibit W-13 is also made out to MAZGANI in
21 different handwriting from the other lines. W14-16 are all made out to
22 Mazgani.
23 CLASS ACTION ALLEGATIONS
24 104. Plaintiff seeks to represent a statewide class defined as follows:
25 105. Plaintiff brings this action as a class action under Federal Rule of Civil
26 Procedure 23.
27 106. Plaintiff seeks to certify a class pursuant to Fed. R. Civ. Proc. 23(a),
28 23(b), 23(c)(4), and 23(c)(5), if necessary.
Page 26 of 53
1 107. Plaintiff seeks relief on behalf of himself and the following class: All
2 persons who were charged by Defendants, and each of them, for a fee related
3 to obtaining Social Security Administration Benefits or California State
4 Benefits in excess of the established permissible amount pursuant to Code of
5 Federal Regulations 404.1720 from December 23, 2005 to the present.
6 108. Excluded from the class are the Defendants, their family members, this
7 Court, and any Director of Mazgani Social Services, INC.
8 109. Subject to confirmation, clarification and/or modification based on
9 discovery to be conducted in this action, Plaintiff also seeks to represent a
10 sub-class in California, defined as follows: All persons who suffered
11 emotional distress as a result of Defendants threats, aggressiveness and/or

bullish tactics designed to induce them to pay the illegal fees.
12
San Diego, CA 92121
Aperture Law Firm
13 110. Defendants, and each of them, were the agents, servants, employees, co-
14 conspirators, joint venture partners, contractors and alter egos of each of the
15 other Defendants, and at all times mentioned herein, each were acting within
16 the knowledge and direction of each other and within the purpose, scope and
17 course of their agency, service, employment, joint venture and with the
18 express and/or implied knowledge, permission, consent and ratification of the
19 remaining Defendants and each thereby has conspired, approved, aided,
20 abetted, encouraged, incentivized and ratified the acts of the other
21 Defendants.
22 111. While the exact number of members in the Class and Subclass are
23 unknown to the Plaintiff at this time, and can only be determined by
24 appropriate discovery; membership in the class and subclass is ascertainable
25 based upon the records maintained by the Defendant and the SSA. It is
26 estimated that the members of the Class number in the thousands, nationwide.
27 112. The individuals included within the alleged class are so numerous that
28 joinder of each of them would be impractical, and the disposition of the claim
Page 27 of 53
1 in a class action, rather than in numerous individual actions, will benefit the
2 parties, the court and the interest of justice.
3 113. There are questions of law and/or fact common to the class and subclass,
4 including but not limited to: (a) Whether the Defendants made false or
5 misleading statements concerning fees and qualifications for SSA benefits;
6 (b) Whether the Defendants charged illegal fees to their clients/SSA
7 claimants; (c) Whether the Defendants engaged in unlawful, unfair, deceptive
8 or fraudulent business practices, in violation of the Californias Unfair
9 Competition Law (hereinafter UCL), Business and Professions Code
10 17200 et seq.; (d) Whether the Defendants violated Code Fed. Reg.
11 404.1720 and 404.1705; (e) Whether Defendants breached a fiduciary duty;

(f) Whether Defendants violated Californias laws protecting Elderly and
12
San Diego, CA 92121
Aperture Law Firm
13 Disabled Persons; (g) Whether Defendants violated Californias Consumers

14 Legal Remedies Act; (h) Whether Defendants committed fraud; and (i)
15 Whether Defendants violated the Racketeer Influenced and Corrupt
16 Organizations Act (hereinafter RICO).
17 114. Plaintiffs claims are typical of the claims of the class and subclass in
18 that Plaintiff hired MSSI to represent him in his SSA claim and lost money
19 due to being charged an illegal fee for MSSIs services.
20 115. Plaintiffs claims are typical of the claims of the members of the Class
21 because the Plaintiff and all members of the Class have been similarly
22 affected by Defendants common course of conduct since they all relied on
23 Defendants representations concerning the fees to be paid for their
24 representation and assistance in obtaining SSA, California State or US
25 Federal Government benefits.
26 116. The Plaintiff and the members of the Class suffered, and will continue to
27 suffer harm as a result of the Defendants unlawful and wrongful conduct. A
28 class action is superior to other available methods for the fair and efficient
Page 28 of 53
1 adjudication of the present controversy. Individual joinder of all members of

2 the Class is impracticable. Even if individual Class members had the
3 resources to pursue individual litigation, it would be unduly burdensome to
4 the courts in which the individual litigation would proceed. Individual
5 litigation magnifies the delay and expense to all parties in the court system of
6 resolving the controversies engendered by Defendants common course of
7 conduct. The class action device allows a single court to provide the benefits
8 of unitary adjudication, judicial economy, and the fair and efficient handling
9 of all Class members claims in a single forum. The conduct of this action as
10 a class action conserves the resources of the parties and of the judicial system
11 and protects the rights of the class members. Furthermore, for many, if not
most, a class action is the only feasible mechanism that allows an opportunity
12
San Diego, CA 92121
Aperture Law Firm
13 for legal redress and justice.

14 117. Adjudication of individual Class members claims with respect to
15 Defendant would, as a practical matter, be dispositive of the interests of other
16 members not parties to the adjudication, and could substantially impair or
17 impede the ability of other class members to protect their interests.
18 118. A Class Action is in the interest of all class members as the Defendants
19 engaged in active money laundering to conceal the source of their income.
20 Without a class action, the Defendants will not voluntarily refund the money
21 illegally collected from the class, and the individual class members will have
22 no redress, especially since many of them have no idea they were ever ripped
23 off.
24 119. Among the proposed class, there is a well-defined community of interest
25 in the question of law and/or fact involved, affecting the class members.
26 These common questions include, but are not limited to:
27 a. The collection of fees in excess of what the SSA permits from class
28 members.
Page 29 of 53
1 b. The disgorgement of fees received by the Defendants directly from

2 the SSA in violation of CFR 404.1720 et seq.
3 120. Common questions of law and/or fact predominate over questions that
4 affect only individual class members. Plaintiffs claims are typical of those
5 belonging to the members of the class he seeks to represent, and plaintiff can
6 adequately represent the class he seeks to represent.
7 121. While the exact number of members in the Class are unknown to
8 Plaintiff at this time, and can only be determined by appropriate discovery,
9 membership in the class and subclasses is ascertainable based upon the
10 records maintained by Defendants. It is estimated that the members of the
11 Class number in the thousands.

122. Therefore, the Class is so numerous that individual joinder of the entire
12
San Diego, CA 92121
Aperture Law Firm
13 Class is impracticable under Fed. R. Civ. P. 23(a)(1).

14 123. Plaintiff will fairly and adequately represent and protect the interests of
15 the Class. Plaintiff has retained counsel with substantial experience in
16 handling complex class action litigation in general and consumer fraud claims
17 in particular. Plaintiffs are also well connected to the affected population that
18 will likely account for the majority of the class members. Plaintiff and his
19 counsel are committed to vigorously prosecuting this action on behalf of the
20 Class and have the financial resources to do so.
21 124. Mootness: The Plaintiff has standing to represent each member of the
22 class. On April 3, 2017 Mahvash sent Iraj a money order for $500.00,
23 essentially refunding the money he paid to Mahvash at their first meeting on
24 March 1, 2017. Exhibit J. This letter was not an offer of judgment subject to
25 Fed. R. Civ. P. 68. Iraj rejected the $500 money order and gave the check to
26 his attorney of record, who is still in possession of the check. A lawsuit or
27 individual claim becomes moot when a plaintiff actually receives all of the
28 relief he or she could receive on the claim through further litigation. Chen v.
Page 30 of 53
1 Allstate Ins. Co., 819 F.3d 1136, 1144 (9th Cir. 2016) citing generally
2 Campbell-Ewald Co. v. Gomez, 136 S. Ct. 663, 193 (U.S. 2016). A case
3 becomes moot only when it is impossible for a court to grant any effectual
4 relief whatever to the prevailing party. Id. at 1145 (internal citations
5 omitted). Here, the $500 money order does not include any civil penalties or
6 punitive damages that the Plaintiff and the Class are asking for, thus this court
7 can still grant additional effectual relief. Furthermore, "[t]o the extent that
8 defendants may avoid a class action by 'picking off' the named plaintiffs, the
9 class claims are 'inherently transitory' and evade review, making an exception
10 to the mootness rule appropriate." Chen at 1143 (internal citations omitted).
11 Here, the money order was provided to the Plaintiff after filing the first
Complaint in Superior Court, thus the Defendants attempt to pick-off Iraj
12
San Diego, CA 92121
Aperture Law Firm
13 will have no effect on the claims or his representation of the class.

14 125. Standing: Iraj seeks to represent a class of individuals who were
15 defrauded by the Defendants, including those Class Members who are seeking
16 damages under Californias Financial Elder Abuse statutes. Iraj is neither
17 aged 65 or older, nor is he a dependent adult. These Financial Elder Abuse
18 statutes are a remedial statute which is to be liberally construed on behalf of
19 the class of persons it is designed to protect. California Assn. of Health
20 Facilities v. Department of Health Services, 16 Cal.4th 284, 295 (Cal. 1997).
21 Standing under the Elder Abuse Act must be analyzed in a manner that
22 induces interested persons to report elder abuse and to file lawsuits against
23 elder abuse and neglect, and analysis of the issue may be intertwined with
24 other issues in elder abuse cases. Estate of Lowrie, 118 Cal.App.4 th, 220,
25 230 (2nd App., 2004). The Court of Appeal of California, First Appellate
26 District recently ruled on this issue in Mahan v. Charles W. Chan Insurance
27 Agency, Inc., Cal.App. LEXIS 507 (1st App. Dist., 2017). In that case,
28 Plaintiffs alleged that their family trust had been defrauded by Defendant
Page 31 of 53
1 insurance company. When they sued for violations of the Elder Abuse Act,
2 the defense argued that the trust was not aged 65 or older, and thus did not
3 have standing to sue. The court held that the plaintiffs did have standing to
4 sue under the Elder Abuse Act because the issues in the case that give rise to
5 the causes of action were intertwined with other issues in elder abuse cases.
6 Id. at footnote 27. The Court concluded that the plaintiff had sufficiently
7 alleged deprivation and wrongful use by the defendants of their property
8 under the Elder Abuse Act, and granted standing. In this case, the Mazgani
9 Family Fraud forms the basis for every cause of action alleged in this
10 Complaint, and is too intertwined with the other causes of action to be
11 separated.
CAUSES OF ACTION
12
San Diego, CA 92121
Aperture Law Firm
13 FIRST CAUSE OF ACTION

14 INTENTIONAL (ACTUAL) FRAUD (CAL. CIV. CODE 1572)
15 (By Plaintiff and on Behalf of the Primary Class and Sub-Classes as Against
16 Defendants)
17 126. Plaintiff incorporates by reference each and every allegation contained
18 above as though fully set forth herein.
19 127. This cause of action is brought pursuant to California Civil Code 1572.
20 128. Defendants violated and continue to violate 1572 by engaging in the
21 following practices with intent to deceive the Plaintiff and the Class which
22 were intended to induce them to enter the contract: (1) [t]he suggestion, as a
23 fact, of that which is not true, by one who does not believe it to be true; (2)
24 [t]he positive assertion, in a manner not warranted by the information of the
25 person making it, of that which is not true, though he believes it to be true; (3)
26 [t]he suppression of that which is true, by one having knowledge or belief of
27 the fact; (4) [a] promise made without any intention of performing it; or, (5)
28 [a]ny other act fitted to deceive.
Page 32 of 53
1 129. Each named Defendant and doe defendant played a role in furthering the
2 Mazgani Family Fraud. Mahvash and Shohreh work to collect the six checks
3 from their victims, with Mahvash running the show and Shohreh processing
4 the checks and making sure that they are distributed amongst the defendants
5 to deposit or cash. Neyaz and Mahnaz help out by depositing the checks into
6 their personal accounts and then drafting checks back to Mahvash, cashing
7 the check, drafting a check to pay for Mahvashs bills, or using the check or
8 cash to pay a bill or some other debt directly. Nazanin works in the
9 Robertson BLVD office and provides legal support to her mother and MSSI.
10 In return, MSSI refers the SSA claimants who need legal representation over
11 to Nazanin. Nazanin operates her law practice knowing that MSSIs clients
paid an illegal fee for SSA services, but never reveals this fact to her new
12
San Diego, CA 92121
Aperture Law Firm
13 clients. Nazanin also represents the Mazgani Familys legal interests in other
14 matters. Exhibit S. Nazanin ensures that the fraudulent fees are kept secret
15 by lending her services to MSSI so that they do not have to refer out their
16 clients to other attorneys who may discover and report the Mazgani Family
17 Fraud. Finally, Nazanin participated in the check fraud at least once by
18 providing Neyaz with a check for $130 so that Neyaz could funnel it to
19 someone else. Finally, since MSSI is a closely held corporation, each officer
20 and director should answer for the crimes of MSSI.
21 130. Mahvash also makes false representations to the SSA by failing to
22 disclose the $3,000.00 fee that she collects from her clients in installments
23 before and after they receive their SSA benefits. As a result, the SSA
24 authorizes fees in excess of what they normally would if they had known
25 about the fraudulent fees. This causes the claimant to pay MSSI twice. Every
26 named Defendant knows about this practice, and each acts to further the fraud
27 for their own pecuniary benefit. Since Mahvash, Neyaz and Nazanin all own
28 a portion of MSSI, they all benefit from the success of the fraud. A
Page 33 of 53
1 misrepresentation need not be oral; it may be implied by conduct. Thrifty-

2 Tel, Inc. v. Bezenek, 46 Cal.App.4th 1559, 1567 (1996). Shohreh furthers the
3 fraud as an employee at MSSI and Mahnaz aids the family by laundering
4 money.
5 131. Defendants also induced Plaintiff and Class members to continue to
6 remit payments under threat that they would forfeit their rights to receive the
7 benefit for which Defendants represented their interests. Since the majority
8 of the blank checks are cashed after a claimant receives their benefits, the
9 Defendants must make sure that the claimants do not try to cancel the checks
10 or have their benefits deposited in a different account that Mahvash does not
11 have access to.

132. Defendants knew they could not bill the Plaintiff or the Class members
12
San Diego, CA 92121
Aperture Law Firm
13 before submitting requests to the SSA because they subsequently submitted

14 those requests after taking payment from the Plaintiff and the Class members.
15 133. Defendants knew that an audit from the SSA would reveal their fraud, so
16 they engaged in money laundering by requiring the class to provide them with
17 blank checks so that they could deposit the checks in different accounts, or
18 cash them at the issuing bank, and then deposit the cash into a personal
19 account.
20 134. Plaintiff and Class members would not have made any payments to
21 Defendants had they known the Defendants were lying about the legality of
22 the initial $3,000.00 fee.
23 135. Plaintiff and Class members reliance on Defendants misrepresentations
24 were reasonable because they are a vulnerable and isolated population who
25 enlisted the aid of the Defendants, with whom a fiduciary duty was created
26 upon Defendants acceptance of that representation pursuant to 20 CFR
27 404.1705. The Plaintiff and the Class hired the Defendants because they were
28 ignorant of the SSAs complicated application procedures and because most
Page 34 of 53
1 of the forms are in English with no Farsi translation available. The Plaintiff
2 and Class members relied on the Defendants representations as to the
3 contents of those forms and the requirements of the SSA to obtain benefits.
4 The Defendants and the Class had no practical way to verify if they were
5 being lied to.
6 136. As a result of the Defendants misrepresentations, Plaintiff and Class
7 members were financially harmed when they were overcharged for MSSIs
8 Representative services.
9 137. Pursuant to Cal. Civ. Code 1572 Plaintiff and Class members seek an
10 order of this Court awarding Plaintiff and the Class restitution, disgorgement,
11 damages and punitive damages.

SECOND CAUSE OF ACTION
12
San Diego, CA 92121
Aperture Law Firm
13 UNFAIR AND DECEPTIVE BUSINESS PRACTICES (CAL. B&P 17200 et

14 seq.)
15 (By Plaintiff and on Behalf of the Primary Class and Sub-Classes as Against
16 Defendants)
19 139. A violation of Californias Unfair Competition Law (hereinafter UCL)
20 occurs when one engages in any unlawful, unfair or fraudulent business act
21 or practice. Cal. Bus. & Prof. Code 17200. Under Section 17200 et seq.,
22 any unlawful, unfair or fraudulent business act or practice and unfair,
23 deceptive, untrue or misleading advertising is deemed to be unfair
24 competition. Id. Section 17200 is written in the disjunctive, it establishes
25 three varieties of unfair competition--acts or practices which are unlawful, or
26 unfair, or fraudulent. In other words, a practice is prohibited as 'unfair' or
27 'deceptive' even if not 'unlawful' and vice versa. Heighley v. J.C. Penney
28 Life Ins. Co., 257 F. Supp. 2d 1241, 1259 (C.D. Cal. 2003) (internal citation
Page 35 of 53
1 omitted).
2 140. The UCL, Business and Professions Code 17200 prohibits any unfair,
3 deceptive, untrue or misleading advertising. For the reasons discussed
4 above, Defendants have engaged in unfair, deceptive, untrue and misleading
5 advertising, and continues to engage in such business conduct, in violation of
6 the UCL.
7 141. The UCLs three prongs are read in the disjunctive, and the UCL
8 separately prohibits any unlawful business act or practice. Defendants
9 violated the UCLs prohibition against engaging in unlawful acts and
10 practices by, inter alia, making the representations and omissions of material
11 facts, as set forth more fully herein, and by violating, among others, 20 CFR
404.1717, 404.1720, 404.1725, 404.1730, Welf. & Inst. Code
12
San Diego, CA 92121
Aperture Law Firm
13 15610.30, 15657.5, Cal. Civ. Code 1572, and the common law. Such
14 conduct is ongoing and continues to this date.
15 142. By engaging in check fraud, money laundering and by charging
16 excessive and illegal fees to their clients, the Defendants have placed
17 themselves at an advantage over other Social Security Representatives who
18 operate their businesses lawfully.
19 143. Plaintiff and the Class reserve the right to allege other violations of law
20 which constitute other unlawful business acts or practices. Such conduct is
21 ongoing and continues to this date.
22 144. Defendants acts, omissions, misrepresentations, practices and
23 nondisclosures as alleged herein also constitute unfair business acts and
24 practices within the meaning of the UCL in that their conduct is substantially
25 injurious to consumers, offends public policy, and is immoral, unethical,
26 oppressive, and unscrupulous as the gravity of the conduct outweighs any
27 alleged benefits attributable to such conduct. In the alternative, Defendants
28 business conduct as described herein violates relevant laws designed to
Page 36 of 53
1 protect consumers and business from unfair competition in the marketplace.

2 Such conduct is ongoing and continues to date.
3 145. Plaintiff also identifies the Defendants violations of consumer
4 protection, unfair competition and truth in advertising laws in California
5 resulting in harm to consumers. Plaintiff asserts violations of public policy
6 through Defendants engagement in false and misleading advertising, unfair
7 competition and deceptive conduct towards consumers. This conduct
8 constitutes violations of the unfair prong of the UCL. Such conduct is
9 ongoing and continues to this date.
10 146. There were reasonably available alternatives to further Defendants
11 legitimate business interests, other than the conduct described herein.

147. Defendants claims, nondisclosures (i.e., omissions) and misleading
12
San Diego, CA 92121
Aperture Law Firm
13 statements, as more fully set forth above, were false, misleading and/or likely
14 to deceive a reasonable consumer within the meaning of the UCL. Such
15 conduct is ongoing and continues to this date.
16 148. Defendants conduct caused and continues to cause substantial injury to
17 Plaintiffs and the other Class members. Plaintiff has suffered injury in fact as
18 a result of the Defendants unfair conduct.
19 149. Defendant has thus engaged in unlawful, unfair and fraudulent business
20 acts and practices and false advertising, entitling Plaintiff and the Class to
21 injunctive relief against Defendant, as set forth in the Prayer for Relief.
22 150. Pursuant to Business and Professions Code 17203, Plaintiff and the
23 Class seek an order requiring Defendant to immediately cease such acts of
24 unlawful, unfair and fraudulent business practices and requiring Defendant to
25 engage in a corrective advertising campaign.
26 151. The Plaintiff, on behalf of himself and the Class, also seeks an order for
27 the disgorgement and restitution of all monies from the sale of the services
28 they purchased, which was unjustly acquired through acts of unlawful, unfair,
Page 37 of 53
1 and/or fraudulent competition. The Plaintiff, on behalf of the Class and

2 himself, further seeks an order for prospective and retrospective injunctive
3 relief.
4 152. Tolling applies to the UCL under a recent decision by the California
5 Supreme Court, Aryeh v. Canon Bus. Sols., Inc., 55 Cal. 4th 1185, 1191-
6 1202 (2013). The silence about tolling and accrual of claims under the
7 UCL trigger[ed] a presumption in favor of permitting settled common
8 law accrual rules to apply and the UCL is governed by common law
9 accrual rules to the same extent as any other statute. DC Comics v. Pac.
10 Pictures Corp., 2:10-CV-03633-ODW, 2013 WL 1389969 (C.D. Cal. Apr.
11 4, 2013) (citing Aryeh, 55 Cal. 4th at 1193).

THIRD CAUSE OF ACTION
12
San Diego, CA 92121
Aperture Law Firm
13 VIOLATION OF THE FALSE ADVERTISING LAW (Cal. B&P 17500, et

14 seq.)
15 (By Plaintiff and on Behalf of the Primary Class and Sub Classes as Against
16 Mahvash, Shohreh and Mazgani Social Services, Inc.)
19 154. The Plaintiff has standing to pursue this claim as the Plaintiff has
20 suffered injury in fact as a result of the Defendants actions as set forth herein.
21 Specifically, prior to the filing of this action, Plaintiff purchased the
22 Defendants services in reliance upon Defendants marketing claims.
23 Plaintiff paid the initial fee required by the Defendants, but has yet to be
24 provided any of the promised benefits.
25 155. Defendants business practices as alleged herein constitute unfair,
26 deceptive, untrue, and misleading advertising pursuant to California Business
27 and Professions Code section 17500, et seq. because Defendants advertised
28 their services, Plaintiff purchased those services in reasonable reliance on
Page 38 of 53
1 Defendants representations and advertisements which were ultimately

2 communicated in a manner that was untrue and misleading, and that is known
3 or reasonably should have been known to Defendants that their
4 advertisements and representations were untrue and/or misleading.
5 156. Defendants frequently advertise their services in Farsi language
6 publications and online in both English and Farsi. Exhibits A-F. The
7 Defendants claim to have substantial knowledge in providing representation
8 to people seeking to file a claim for SSA benefits. Id. See also Dkt. 11-2
9 6-9. In reliance on their advertisements and representations, Plaintiff and
10 Class members sought out the Defendants services to aid in their applications
11 for SSA benefits. The Plaintiff and Class members relied on the Defendants
claims of experience and knowledge in their advertising when agreeing to pay
12
San Diego, CA 92121
Aperture Law Firm
13 the illegal $3,000 fee for their services. The Plaintiff and Class members also
14 relied on the Defendants advertisements when they were told that failure to
15 pay the illegal $3,000 fee would cause them to forfeit their SSA benefits.
16 157. As such, Plaintiff and Class members paid either all or a portion of the
17 $3,000 fee as required by the Defendants. Defendants wrongful business
18 practices have caused injury to the Plaintiff and the Class.
19 158. Pursuant to section 17203 of the California Business and Professions
20 Code, the Plaintiff and the Class seek an order of this court enjoining
21 Defendants from continuing to engage in deceptive business practices, false
22 advertising, and any other act prohibited by law, including those set forth in
23 the complaint. Plaintiff also seeks an order for the disgorgement and
24 restitution of all monies from the sale of the services which were unjustly
25 advertised through acts of unlawful, unfair, and/or fraudulent competition.
26 FOURTH CAUSE OF ACTION
27 BREACH OF FIDUCIARY DUTY (20 CFR 404.1705)
28 (By Plaintiff and on Behalf of the Primary Class and Sub Classes as Against
Page 39 of 53
1 Mahvash, Neyaz, Nazanin, Shohreh, and Mazgani Social Services Inc.)

4 160. A fiduciary relationship is any relation existing between parties to a
5 transaction wherein one of the parties is in duty bound to act with the utmost
6 good faith for the benefit of the other party. Such a relation ordinarily arises
7 where a confidence is reposed by one person in the integrity of another, and in
8 such a relation the party in whom the confidence is reposed, if he voluntarily
9 accepts or assumes to accept the confidence, can take no advantage from his
10 acts relating to the interest of the other party without the latters knowledge or
11 consent. (Wolf v. Superior Court, 107 Cal.App.4th 25, 29 (Ct. App. 2nd
Dist., 2003), (internal citations omitted).
12
San Diego, CA 92121
Aperture Law Firm
13 161. Every agent owes his principal the duty of undivided loyalty. During
14 the course of his agency, he may not undertake or participate in activities
15 adverse to the interests of his principal. In the absence of an agreement to the
16 contrary, an agent is free to engage in competition with his principal after
17 termination of his employment but he may plan and develop his competitive
18 enterprise during the course of his agency only where the particular activity
19 engaged in is not against the best interests of his principal. Sequoia Vacuum
20 Systems v. Stransky, 229 Cal.App.2d 281, 287 (1964).
21 162. A fiduciary must give "priority to the best interest of the beneficiary."
22 Committee on Children's Television, Inc. v. General Foods Corp., 35 Cal.3d
23 197, 222 (1983).
24 163. A fiduciary is also is required to manage the subject matter of the
25 relationship (or res) with due care and must account to the beneficiary and
26 keep the beneficiary fully informed as to all matters pertinent to the
27 beneficiary's interest in the res. See Chodos, The Law of Fiduciary Duties
28 (2000), pp. LIV-LV.
Page 40 of 53
1 164. [B]efore a person can be charged with a fiduciary obligation, he must

2 either knowingly undertake to act on behalf and for the benefit of another, or
3 must enter into a relationship which imposes that undertaking as a matter of
4 law. Committee on Childrens Television, Inc. v. General Foods Corp., 35
5 Cal.3d 197, 221 (1983).
6 165. The Defendants hold themselves out to the public as a Social Services
7 Agency in the business of representing the general public in their Social
8 Service/Government Benefit claims. To do this, Defendants must sign a
9 notice appointing that person as their representative, and submit that notice to
10 the Social Security Agency. See 20 CFR 404.1707.
11 166. As an SSA Representative, the Defendants must adhere to the SSAs

rules and regulations. Representatives who are not attorneys must be capable
12
San Diego, CA 92121
Aperture Law Firm
13 of giving valuable help to you in connection with your claim and must be
14 generally known to have a good character and reputation. 20 CFR 404.1705.
15 Attorneys must abide by the California Rules of Professional Conduct, and
16 must not otherwise be forbidden from representing their client. Id. As such,
17 the Representative is authorized to (1) [o]btain information about your claim
18 to the same extent that you are able to do; (2) [s]ubmit evidence; (3) [m]ake
19 statements about facts and law; and (4) [m]ake any request or give any notice
20 about the proceedings before [the SSA]. 20 CFR 404.1710. Finally, the
21 SSA forbids any Representative to commit any improper acts including;
22 [k]nowingly and willingly furnishing false information, and [c]harging or
23 collecting an unauthorized fee, or charging or collecting too much for services
24 provided in any claim, including services before a court that made a favorable
25 decision. Exhibit O-4. The SSA states that if you commit any improper
26 act that you can be disqualified from representing anyone before the SSA or
27 you can face criminal prosecution. Id.
28 167. As such, a fiduciary duty exists between the Plaintiff and Defendants as
Page 41 of 53
1 a principal and agent. A fiduciary duty between a principal and agent is

2 imposed by California law. See Oakland Raiders v. National Football
3 League, 131 Cal.App.4th 621 (2005) and Recorded Picture Company
4 [Productions] Ltd. v. Nelson Entertainment, Inc., 53 Cal.App.4th 350, 369-
5 370 (1997).
6 168. As officers and/or employees of MSSI, a fiduciary duty exists between
7 the Plaintiff as the Class representative and Mahvash, Neyaz, Nazanin,
8 Shohreh and MSSI. The SSA requires that: (1) the Representative must be
9 known for having a good character and reputation; and (2) that the
10 Representative must be capable of providing valuable help to the claimant.
11 These requirements along with all the regulations concerning how the
Representative is allowed to collect their fees from the claimant, impose a
12
San Diego, CA 92121
Aperture Law Firm
13 duty of loyalty on the Defendants more so than would a mere contract or a

14 debt, and have a strong tendency to demonstrate the existence of a fiduciary
15 duty. Wolf v. Superior Court, 107 Cal.App.4th 25, 30-31, 33-34 (2003).
16 169. The Defendants breached their duty of loyalty when they knowingly
17 acted against the interests of the Plaintiff by requiring Plaintiff and Class
18 members to pay erroneous and illegal charges for their services up front and
19 after receiving SSA benefits, causing the Plaintiff and Class financial loss and
20 hardship.
21 170. The Defendants also breached their duty of reasonable care when, after
22 assuming their roles as the Plaintiffs agents for the purposes of representing
23 the Plaintiff to apply for SSA benefits, Defendants failed to act as a
24 reasonably careful agent would have acted under similar circumstances by
25 charging the Plaintiff in an amount and manner inconsistent with the statutory
26 requirements of such a relationship, causing financial loss and hardship to the
27 Plaintiff. Defendants willful acts were a direct cause of Plaintiffs financial
28 damages.
Page 42 of 53
1 171. The Defendants also breached their duty of loyalty by collecting

2 information during the interview process for the sole purpose of making
3 threats and intimidating the claimants into paying their illegal fees after the
4 SSA benefits were received. As stated above, Defendants acts of fraud and
5 inducement also breached their fiduciary duty with the Plaintiff, causing him
6 financial and emotional harm.
7 172. Pursuant to Californias common law Breach of Fiduciary Duty, the
8 Plaintiff and the Class seek restitution damages, disgorgement, and punitive
9 damages.
10 FIFTH CAUSE OF ACTION
11 INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

(By Plaintiff on behalf of himself and those Class Members Who Suffered
12
San Diego, CA 92121
Aperture Law Firm
13 Emotional Distress, Against Mahvash, Shohreh, Mazgani Social Services Inc.,

14 and DOES 1-10)
17 174. Defendants use of their agency relationship to gain access to the
18 Plaintiff and similarly situated Class members to bully, harass, threaten, and
19 manipulate through lies and intimidation for their own financial gain is
20 offensive enough. When that conduct is directed at some of the most
21 vulnerable members of our society (the elderly and the disabled), the
22 Defendants conduct becomes outrageous.
23 175. Mahvash and Shohreh knowingly take advantage of the elderly and
24 disabled because they know that they are easy victims, especially when they
25 are already isolated from the rest of society through language and ethnic
26 barriers. Since 2005 (and possibly earlier) Mahvash and Shohreh have been
27 taking advantage of the most vulnerable individuals in our society by acting
28 as additional gate-keepers to a government program that is designed to help
Page 43 of 53
1 alleviate their suffering, not cause more of it.

2 176. Shohreh aids Mahvash in obtaining information about the family
3 members and other loved ones of the claimants so that Mahvash and her
4 agents can strong-arm them into paying their illegal fees. Here, Shohreh
5 actively recorded the names of Irajs family members during their initial
6 interview so that she could provide their contact information to Mahvash.
7 Further, Shohreh also maintains MSSIs records, including information about
8 a claimants family that she knows is irrelevant to their claim.
9 177. After their initial interview, Iraj questioned the $3,000 fee demanded by
10 Mahvash and was subjected to a barrage of follow-up phone calls from
11 Mahvash fraudulently claiming that the full $3000.00 fee was required in
order for Iraj to receive SSA benefits, and if he prevented them from cashing
12
San Diego, CA 92121
Aperture Law Firm
13 the checks he would forfeit his benefits. Things got so bad that Iraj was
14 having trouble sleeping; he was constantly worrying about how he was going
15 to make ends meet, and even more troubling, where he was going to get the
16 money to pay off Mahvash if his claim was ultimately denied. Eventually,
17 Iraj stopped answering Mahvashs phone calls.
18 178. His friends and family suggested that he speak with a lawyer when they
19 heard that Mahvash was asking him to provide her blank checks in order to
20 pay her fee. Iraj and the Class suffered financial and emotional harm through
21 the actions of Mahvash and her family.
22 179. Irajs wife suffered an anxiety attack when one of Mahvashs agents
23 threatened her on the telephone.
24 180. Pursuant to Californias common law intentional infliction of emotional
25 distress, Plaintiff is asking for compensatory damages in an amount according
26 to proof at trial.
27 SIXTH CAUSE OF ACTION
28 FINANCIAL ELDER ABUSE (Welf. & Inst. Code 15610.30 & 15657.5)
Page 44 of 53
1 (By Plaintiff on Behalf of those Class Members Who Were Age 65 and Older
2 When they Were Charged Illegal Fees from Defendants, and Against all
3 Defendants)
6 182. Even though Iraj is not aged 65 or older he may still represent those
7 Class members who are aged 65 and over because the basis for the Elder
8 Abuse claim arises out of the exact same fraud perpetrated by the Defendants.
9 Code of Fed. Reg. 404.1720 and 404.1705 also apply to those individuals
10 aged 65 and older who are seeking SSI benefits as well as those seeking SSD
11 benefits. The analysis for Elder Abuse mirrors the analysis used for common
law fraud above, and arises out of the exact same set of circumstances and is
12
San Diego, CA 92121
Aperture Law Firm
13 against the exact same defendants.

14 183. Californias Elder Abuse and Dependent Adult Civil Protection Act
15 protects the elderly from being ripped-off by predatory con-artists. Financial
16 abuse of an elder or dependent adult occurs when a person or entity: (1) takes
17 real or personal property for a wrongful use or with intent to defraud; (2)
18 assists in taking the real or personal property of an elder for a wrongful use of
19 with intent to defraud; or (3) takes real or personal property of an elder by
20 undue influence. Cal. Wel. And Inst. Code 15610.30.
21 184. As discussed in greater detail above, Defendants Mahvash and Shohreh
22 appropriated Irajs money to help him apply for SSD benefits during Irajs
23 first meeting with at the MSSI office. Mahvash and Shohreh also took 5
24 additional checks from Iraj so that they could collect the remaining $2,500 of
25 their $3,000 fee.
26 185. Mahnaz and Neyaz provide assistance to Mahvash and MSSI by
27 laundering the money they con out of their clients through different accounts
28 as discussed in more detail above.
Page 45 of 53
1 186. Nazanin provides legal representation to MSSI and the other Defendants
2 and operates, with knowledge of the fraud, out of the same building as MSSI.
3 187. Defendants were working in conjunction with each other and for their
4 mutual benefit by either directly committing the fraud, or by facilitating its
5 commission through aid and/or encouragement.
6 188. In fact, Defendants were pocketing the extra money they were
7 appropriating from the Plaintiff and the Class members, and billing the SSA
8 as if they had never requested illegal fees. The Plaintiff was caused financial
9 loss and emotional hardship as a direct result of the Defendants actions.
10 189. Depending on the specific award from the SSA, Defendants would have
11 either received a percentage of the benefit payment, or would have been paid
directly from the SSA for their representation.
12
San Diego, CA 92121
Aperture Law Firm
13 190. As argued above, Defendants acted with purpose, intent and knowledge
14 when they committed fraud and appropriation, and their conduct was
15 objectively outrageous.
16 191. The Class was injured when the Defendants appropriated their money
17 through fraud, threats and misrepresentation.
18 192. Pursuant to Californias Elder Abuse and Dependent Adult Civil
19 Protection Act, Plaintiff is asking for compensation for mental suffering,
20 emotional distress, punitive damages, compensatory damages and all
21 enhanced remedies provided by 15610.30.
22 SEVENTH CAUSE OF ACTION
23 Violation of RICO (18 USC 1961 et seq.)
24 (By Plaintiff on Behalf of himself, the Primary Class, and all Sub Classes,
25 Against All Defendants including DOES 1 through 25)
28 194. This cause of action arises under the Racketeer Influenced and Corrupt
Page 46 of 53
1 Organizations Act, 18 U.S.C. 1961 et seq.

2 195. Defendants, and those in the conspiracy, willfully and intentionally
3 violated and continue to violate RICO and California law with the goal of
4 obtaining money, directly and/or indirectly, through a pattern of racketeering
5 activities in violation of 20 CFR 404.1700 et seq.
6 196. Each of the Defendants are engaged in activities of federal interstate
7 commerce and are persons or entities capable of holding a legal or beneficial
8 interest in property. All Defendants are persons as that term is defined by
9 18 U.S.C. 1961(3).
10 197. The Defendants are engaged in activities of federal interstate commerce
11 when they defraud their victims by taking money out of their SSA benefits as
obtained from the SSA. Furthermore, the Defendants launder the money they
12
San Diego, CA 92121
Aperture Law Firm
13 steal from their victims by funneling it through credit card payments and
14 other debts for each other, and for themselves.
15 198. The Defendants (and each of them) together work in furtherance of the
16 Mazgani Family Fraud as an association of entities and individuals associated
17 in fact to collect, and conceal the source of, illegal fees for services collected
18 from SSA claimants. The Mazgani Family Fraud includes a California
19 Corporation and several members of the Mazgani Family, and is thus an
20 Enterprise as defined in 18 U.S.C. 1961(4).
21 199. Mahvash is the CEO of Mazgani Social Services Inc., and is responsible
22 for processing claimant applications and ensuring that claimants provide the
23 six blank checks required for their illegal $3,000 fee. Mahvash also
24 participates in the money laundering by cashing the $500 checks received
25 from SSA claimants for their $3,000 fee and uses the cash to pay off her
26 personal credit card debts.
27 200. Shohreh works as an employee of MSSI and was present during the
28 initial meeting with Iraj as discussed hereinabove. Shohreh collects and
Page 47 of 53
1 stores the blank checks from the Companys SSA claimants and helps process
2 the paperwork needed for their SSA claims. Shohreh also makes deposits for
3 the Company and distributes the blank checks for laundering once a claimant
4 is approved for SSA benefits.
5 201. Neyaz works at the MSSI office on Robertson BLVD. Plaintiff is
6 ignorant as to her exact role at MSSI. Neyaz participates in the money
7 laundering scheme by: (1) depositing the checks and/or cash into her personal
8 account and then: keeps the money; writes a check for the same amount of
9 money to someone else; using the money to pay off personal debts; and using
10 the money to pay off Mahvashs debts. Neyaz also participates in the money
11 laundering by cashing checks either at the bank from which the check is
drawn or at her own personal bank, and then depositing the cash in her
12
San Diego, CA 92121
Aperture Law Firm
13 personal account where she; funnels the money through credit card companies
14 or by paying off other debts; by providing the money back to Mahvash or
15 another co-conspirator either by check or by paying payments on one of the
16 recipients debts; and/or by using the check to directly pay off a personal debt
17 by drafting the check directly to the creditor.
18 202. Mahnaz participates in the money laundering scheme by taking
19 possession of an SSA claimants $500 check and either depositing it in her
20 account or cashing it. Plaintiff is ignorant of the ultimate destination of the
21 funds.
22 203. Nazanin is a shareholder and director of MSSI who runs her law practice
23 out of MSSIs Robertson BLVD office. Nazanin provides legal
24 representation to MSSI and their agents and employees. Nazanin also
25 represents MSSI claimants who are appealing an SSA decision at a legal
26 proceeding. Nazanin participates in the Mazgani Family Fraud through her
27 proximity to, and fiduciary role with, MSSI and her family.
28 204. MSSI is a closely held corporation by Mahvash, Nazanin and Neyaz.
Page 48 of 53
1 MSSI, through its agents and employees, is the business entity used by the
2 Mazgani Family to provide their SSA representative services. Through this
3 corporation, Mahvash and Shohreh send requests to the SSA for wire
4 transfers and/or checks drafted against the benefits awarded to a claimant for
5 their fees. This Corporation is also used to collect the additional illegal
6 $3,000 fee from SSA claimants.
7 205. Defendants are required to complete all requests for payment through the
8 SSA either by check or wirelessly pursuant to 20 CFR 404.1713. When the
9 Defendants force their victims to pay a fee up front for their services, then
10 subsequently bill the SSA as if they had never received a fee, they are
11 committing wire fraud (if the funds are wired) or mail fraud (if the checks are
mailed), and are in violation of 18 US Code 1343.
12
San Diego, CA 92121
Aperture Law Firm
13 206. The Defendants refuse to assist their victims unless they make the first
14 $500 payment of their $3,000 fee. If a claimant refuses to pay the rest of the
15 $3,000 fee after they receive their SSA benefits, the Defendants engage in a
16 series of threats against the claimants personally, and threaten to have their
17 SSA benefits cancelled. The threats and intimidation used by the Defendants
18 to ensure the collection of their illegal fees is extortion in violation of 18
19 U.S.C. 1951.
20 207. The Defendants are engaged in activities of federal interstate and foreign
21 commerce, and are entities capable of holding a legal or beneficial interest in
22 property. All Defendants are persons, as that term is defined by 18 U.S.C.
23 1961(3). The Defendants engage in money laundering which includes the
24 use of illegal fees to pay personal bills to creditors in interstate commerce.
25 208. Several fraudulent misrepresentations and extortion allegations have
26 been discussed in detail above concerning the Mazgani Family. Mahvash,
27 through MSSI has engaged in systematic wire fraud through misrepresenting
28 payments to the SSA and through concealing the source of the money they get
Page 49 of 53
1 directly from their clients.

2 209. As discussed above, the Mazgani Family has engaged in several
3 instances of Racketeering activity both through interstate commerce, wire
4 fraud, mail fraud and extortion.
5 210. Defendants are liable to Plaintiff and the Class members for treble
6 damages, together with all costs of this action plus reasonable attorneys fees,
7 all as provided under 18 USC 1964(c), the Business and Professions Code and
8 all other causes of action pled above.
9 Prayer for Relief
10 WHEREFORE, given the foregoing, Plaintiffs pray for relief as set forth above
11 and as follows:
A. That the Court assume jurisdiction in this case and grant a jury trial and
12
San Diego, CA 92121
Aperture Law Firm
13 expedited trial under California elder abuse statutes;

14 B. That the Court award actual and compensatory damages in an amount to be
15 proven at trial, (but no less than the jurisdictional minimum of this
16 Court);
17 C. That the Court award reasonable costs and attorney fees to Plaintiff under
18 Californias Elder abuse statute, California Civil Code 1021.5, and
19 through other causes as argued above;
20 D. That the Court allow punitive damages designed to punish and deter
21 Defendants from engaging in similar future conduct;
22 E. That the Court award treble damages and that monetary penalties be
23 assessed to each Defendant;
24 F. That the Court order all the transactions VOID and unenforceable and Order
25 that all secret profits and ill-gotten gains be disgorged;
26 G. The defendants must be subjected to a detergent theory of disgorgement of
27 all income derived from representation of any class member before the
28 SSA for period of 2005-2017 (and onward till the day of judgment).
Page 50 of 53
1 H. Injunctive Relief;
2 I. Appointment of a Receiver (to take hold of any incoming proceeds to the
3 Defendants and to assist in accounting for all illicit profits of the
4 enterprise);
5 J. For a temporary restraining order against all named Defendants and Does 1-
6 25 forbidding them to come within 50 yards of Iraj and his family;
7 K. For preliminary discovery to find additional class members and to warn
8 them about the Defendants fraud;
9 L. For an asset freeze and accounting to ensure that the Class can obtain full
10 justice by having their property secured and restored to them;
11 M. To order the Defendants to publish corrective advertisements informing the

Iranian community of the illegality of collecting administrative fees
12
San Diego, CA 92121
Aperture Law Firm
13 directly from SSA claimants for Representation;

14 N. That the Court award such other and further relief as the Court deems just
15 and proper.
16
17 RESPECTFULLY SUBMITTED
18
Dated: June 14, 2017
19
20 /s/
21 Robert B. Salgado, Esq.
Attorney for Plaintiff Iraj Khosroabadi
22
23
24
25
26
27
28
Page 51 of 53
1 PROOF OF SERVICE
2 Khosroabadi v. Mazgani Social Services, Inc. et al.

Case No. 8:17-cv-00644-CJC-KES
3
4 United States District Court )
) ss.
5 Central District of California )
6
7 I am employed in the County of San Diego, State of California, I am
over the age of 18 and not a party to the within action; my business address
8 is 5755 Oberlin Drive, Suite 301, San Diego, CA 92121.
9 On this date, I served the foregoing document(s) described as:
10 1. CIVIL CASE COVER SHEET;
11 2. PLAINTIFFS FIRST AMENDED COMPLAINT AND EXHIBITS;

12 3. DECLARATION OF IRAJ KHOSROABADI IN SUPPORT OF

PLAINTIFFS FIRST AMENDED COMPLAINT ;
San Diego, CA 92121
Aperture Law Firm
13
4. AMENDED NOTICCE OF INTERESTED PARTIES;
14
15
5. NOTICE OF LODGMENT;
16 on the parties indicated below and/or their attorney(s) of record to this action by
emailing a true copy thereof, as follows:
17
SERVICE LIST
18 Felton Newell Attorney for Defendants
12777 W. Jefferson Blvd., Bldg. D, STE. 300 Mazgani Social Services, INC.
19 Playa Vista, CA 90066 Mahvash Mazgani
felton@thenewelllawfirm.com Nazanin Mazgani
20 Neyaz Mazgani
21 BY E-MAIL. On this date, by electronic transmission (e-mail) to the parties and/or
to their attorney(s) of record stated above and/or attached list to their known e-mail
22 address(es). The document(s) was/were transmitted by electronic transmission. The
transmission was reported as complete and without error.
23
24 BY ECF. Filed and served electronically in accordance with the Courts electronic
25
filing (ECF) rules, pursuant to which registered ECF users receive service copies
by e-mail delivery.
26
27 STATE: I declare under penalty of perjury under the laws of the State of California
that the foregoing is true and correct. FEDERAL: I hereby certify that I am
28 employed in the office of a member of the Bar of this Court at whose direction the
service was made, and I certify under penalty of perjury that the foregoing is
Page 52 of 53
true and correct.

1
2 Executed on this 14th day of June, 2017, at San Diego, California.
3
4 /s/ Robert Salgado
5 Robert B. Salgado, Attorney for
Plaintiff Iraj Khosroabadi
6
7
8
9
10
11
12
San Diego, CA 92121
Aperture Law Firm
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Page 53 of 53
Case 8:17-cv-00644-CJC-KES Document 15-3 Filed 06/14/17 Page 1 of 3 Page ID #:336
1 Aperture Law Firm

Robert B. Salgado, Esq. (SBN 297391)
2 robert@aperturelaw.com
Telephone: 858-223-6552
4 Fax: 858-223-6557
5 Attorney for Plaintiff: Iraj Khosroabadi
6
7
8
9

12
)
San Diego, CA 92121
Aperture Law Firm
13 IRAJ KHOSROABADI, an Individual ) Case: 8:17-cv-00644-CJC-KES

)
14 Plaintiff, )
) DECLARATION OF IRAJ
15 vs. ) KHOSROABADI IN SUPPORT OF
MAZGANI SOCIAL SERVICES, INC, ) PLAINTIFFS FIRST AMENDED
16 ) COMPLAINT
a California Corporation, MAHVASH )
17 MAZGANI, NAZANIN MAZGANI, ) Honorable Cormac J. Carney
NEYAZ MAZGANI, MAHNAZ )
18 )
MOGHADDAM, SHOHREH )
19
SHARIFZADEH, and DOES 1 through ))
20 25, inclusive, )
)
21 Defendant(s) )
)
22 ________________________________ )
23
24
25
I, Iraj Khosroabadi do hereby declare that:
26
1. My name is Iraj Khosroabadi and I am a resident of Los Angeles, CA.
27
2. I have first-hand knowledge of the claims contained in 34-61 of
28
Plaintiffs First Amended Complaint.
Page 1 of 2
DECLARTION SUPPORTING PLAINTIFFS FIRST AMENDED COMPLAINT
1 3. I have reviewed Plaintiffs First Amended Complaint and verify that

2 the claims made in 34-61 are true and correct to the best of my recollection.
3 I declare under penalty of perjury under the laws of the State of California that
4 the foregoing is true and correct.
5
6 Executed this 14th day of June, 2017 at Los Angeles, California.
7
8
9 Iraj Khosroabadi
10 ________________
11
12
San Diego, CA 92121
Aperture Law Firm
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Page 2 of 2
DECLARTION SUPPORTING PLAINTIFFS FIRST AMENDED COMPLAINT
3. I have reviewed Plaintiff's First Amended Complaint and verify that

2 the claims made in ,i,i 34-61 are true and correct to the best ofmy recollection.
3 I declare under penalty of pe~jury under the laws of the State of California that
4 the foregoing is true and correct.
5
6 Executed this 14th day of June, 2_9_!]_,:i,tLas.~""""=-"
,,-----
7 /
8
"---""----- __......,
9
lraj Khosroabadi
10
18
19
20
21
22
23
24
25
26
27
28
Page 2 of2
DECLARTION SUPPORTING PLAINTlr'fS l'JRST AMENDED COMPLAINT
EXHIBIT A
CASE: 8:17-cv00644-CJC-KES
KHOSROABADI v. MAZGANI ET AL
PLAINTIFF'S EXHIBIT A
MAHVASH MAZGANI
310-273-5228 mahvashmazgani@gmail.com
949-975-0874 1110 S.ROBERTSON BLVD.#3
LOS ANGELES, CA
ATTORNEYS SERV. BUREAUS, ORANGE COUNTY

,(
)
PLAINTIFF'S EXHIBIT A-1
~ WJJ:-l~
w ~J,j,
wtn Hj~ J;:,. ,~ ,S!.M

SSA ,SSI ri'.J.-, J.-,- .i~
SDI , CAPI ..J~ti1J'4 :,t Jtit'
(949) 7
0874
Ora I County
(31 OJ 273 5228
110S.R RTSONBI d. u e3
I , CA 90035
178 KHOSROABADI v. MAZGANI ET AL
EXHIBIT B
PLAINTIFF'S EXHIBIT B
J ''.Ji.. ' w ~~~IS'

.. '..r'='
Law Offices of N azanin Mazgani

Itnm.igration
~~~~u, ~ f t ~ ..J~1 ~
y ...,,,,
-._, x 'x'
" ....~. ,JI/II~ t,,.,.$7:, ,,, ~.4111"U- ~...r ~
...1, ,.t,,3' ~ft~~~, ~, ~

~..),~ 'Y.~y,J ~~, ~
~~, jf ~~' jf 4.5y.l~ ~
Personal Injury / Accidents
~~ ~~->ee I ~L.~,.~
Social Security Disability
(Initial Filings and Hearings)
~ ~l;.;.jf llf jf ~ ~~y\) J>
424 256 - 0095
310 892 - 0820
11400 W. Olyni_pic Blvd.,Suite 20
Los Angefes, CA 90064
PLAINTIFF'S EXHIBIT B-1
224
EXHIBIT C
PLAINTIFF'S EXHIBIT C
~~~~~~
~~p
THE IRANIAN POCKET DIRECTORY YELLOW PAGES
29 th Edition
'5~ - 15,ai - "5~~ - "5~ J~ l"!Jii
www.lran411.com
310.IRAN411
PLAINTIFF'S EXHIBIT C-1
........ ".... \..o-'r
. D "I ,~
EXHIBIT D
PLAINTIFF'S EXHIBIT D
Case 8:17-cv-00644-CJC-KES Document 15-4 Filed 06/14/17 Page 10 of 77 Page ID
#:348
C 0 mazganilaw.com/ practice-areas/ immigration/social-security-disability-and-ssi/
~ ~ I~t I
I\i Nazanin
SELECT LANGUAGE I y
~._,fi
~ ,"- .
Law Offices of CALL US NOW!
(310) 892-0820
Mazgani 11400 W. Olympic Boulevard, Suite 200
Los Angeles, California 90064
HOME ATTORNEY PRACTICE AREAS F.A.Q TESTIMONIALS USEFUL LINKS CONTACTS
PRACTICE AREAS Social Security Disability and SSI

A Immigration
Helping to obtain California Social Security disability benefits
> Visas for claimants throughout Los Angeles and Southern California.
> Citizenship
Social Security pays benefits to people who can't work
> Green Cards because they have a medical condition that's expected to last
> Asylum / Refugee at least one year or result in death. Federal law requires this
> Work Permits very strict definition of disability. While some programs give
money to people with partial disability or short-tem1 disability,
> Family Immigration Social Security does not.
> Provisional Waivers
> Dream Act Certain members of your family may qualify for benefits
based on your work. They include:
> Obama's Executive Actions Your spouse, if he or she is age 62 or older;
> Temporary Protected Status Your spouse at any age, if he or she is caring for a child of
yours who is younger than age 16 or disabled;
A Social Security Disability and 551 Your unmarried child, including an adopted child, or in some
cases, a step child or grandchild. The child must be younger than age 18 (or younger than 19 if still in high
A Personal Injury ( Car Accident) school);
Your unmarried child, age 18 or older, if he or she has a disability that started before age 22. The child's
A Surplus Funds Collection Offer disability must also meet the definition of disability for adults.
A Trustee Sale
The Law Offices of Nazanin Mazgani provide disability claimants legal help through all four stages of the
disability process.
Will you qualify for Social Security disability benefits?

It depends on your age, education, recent jobs, and ability to work.
PLAINTIFF'S EXHIBIT D-1
#:349
EXHIBIT E
PLAINTIFF'S EXHIBIT E
#:350
f- C [ (D www.best iran ianlawyers.com/m-o/
<[]morn>
Best Iranian Lawyers
Home I A-D I E-H I I-L I M-0 I P-R I S-Z I By State I w\i ~~ I ~~ .J_,..1 I ...::.,'.;\JJ .Jl.....=.jl I
_;\!..J.J4 .J _,..I
California Iranian Lawyers M-0
Mazgani, Nazanin
1110 S. Robertson Blvd., #1
Los Angeles, CA 90035
424-256-0095
310-892-0820
mazganilmv@ginail.com
Mafi, Maziar
1502 N Broadway.,
CASE: 8:17-cv-00644-CJC-KES Santa Monica, CA
KHOSROABADI v. MAZGANI et al. 714-543-3350
714-624-1285
PLAINTIFF'S EXHIBIT B 310-991-4243
Fax: 714-543-2277
maziar@mafilaw.com
PLAINTIFF'S EXHIBIT E-1
#:351
~ C Ii Secure I https://www.checkbca.org/report/law-offices-of-nazanin-mazgani-100
....
--
. ~ BUSINESS -CONSUMER
, . . ALLIANCE.
nin Mazgani File Complaint
Company Rating
vd.# 1
T he rating assigned to a business is
determined by our compos ite score of such
facto rs as its type of business...
Full Rating Explanat ion -

Website:
Social: Membership Information

Hours: Mo nday Friday 9am- 5pm
T his bus iness fs nota,rnernber of Business Consumer Alliance. This
Primary Contact: Nazanin Mazgani (Owner) fact does not d isparage the company in.anyway.
Business Started: 6/'.1/2010 Are you lookif1gfor reputable Personal

l11ury Attorney? Member Directory
Browse our Membe"r Dir ectory and
This company 's b~1siness is provid ing personal inj ury. immigr at io n. shop with confidenGe 1
and ciV il attorney se,v ices.
331 inquiries See more photos and v ideos on Business Review s -
...
PLAINTIFF'S EXHIBIT E-2
#:352
EXHIBIT F
PLAINTIFF'S EXHIBIT F
#:353
PLAINTIFF'S EXHIBIT F-1
#:354
EXHIBIT G
PLAINTIFF'S EXHIBIT G
#:355
State of California
Secretary of State
05-573170
STATEMENT OF INFORMATION
a------------------------------1 (Domestic Stock Corporation)

FEES (FIiing and Disclosure): $25.00. If amendment, see Instructions.
1.
IMPORTANT- READ INSTRUCTIONS BEFORE COMPLETING THIS FORM
CORPORATE NAME (Please do not alter if name rs prepnnled.)
FILED
In the offlce of 1M Secretary of State
of the State of Callromla
Ml\ Z.c;ANI soc," L Si::.~\/1C.S$ l~C...
Cz5o 93,1 DEC ! 3 2005
I 015'-/ MIJ 9SACI-IU.si:FrTS AVE;:.
Lo.s. t,c N &.E' LiF~ 04- loo 2 '7
This Space For Filing Use Only

DUE DATE:
CALIFOR~IA CORPORATE DISCLOSURE ACT (Corporations Code section 1502.1)
A publicly traded corporation must file with the Secretary of State a Corporate Disclosure Statement (Form SI-PT) annually. within 150 days
after the end of its fiscal.year. Please see reverse for additional information regarding publicly traded corporations.
COMPLETE ADDRESSES FOR THE FOLLOWING (Do not abbreviate the name of the cit . llems 2 and 3 cannot be P.O. Boxes.>
2. STREET AOORESS OF PRl"ICIPAL EXECUTIVE OFFICE CITY AND $TATE
10'9SY h?h'SS,4 c,./t1SFTTS re VE. ~,Ev~
. CITY. .
:::'/t-E'Zt::$i,
FOLLOWING OFFICERS (The corporation musl have lhHe three officers. A comparable ti
for the s crfic officer ma be added however lhe re inted liUes on this form must not be allered.
4. CHIEF EXECUTIVE OFFICER/ ADDRESS CITY ANO STATE ZIP CODE
M1'~11'.'1SH (Y'}n2Gt1#1 IO'tSY m,tss,4r11userrS J\-1/c , Lo.S. -A.('Jtr.Et'ES cA CfDDZ.y
5. SECRETARY/ ADDRESS CITY AND STATE ZIP CODE
Ntl"2Atvl/\J /VI rt 2&Ar.tJ 101SV A1~!1I,Ar11t,.sF n.s 1'tE. . ., Los AAl~,r-.{~ S. <;fr 1002)1
6 CHIEF FINANCIAL OFFICER/ ADDRESS CITY ANO STATE ZIP CODE
IJTfy/fZ.. /11//Z&~tlll SY A'/dS'SA<"Ht/StFT?S AV.f'. Lo~ //Aft;Ft'~=-S,, Cj[)l)Ztj
NAMES AND COMPLETE ADDRESSES OF ALL DIRECTORS, INCLUDING DIRECTORS WHO ARE ALSO OFFICERS (The corporation
must have at least one director. Attach additional a es. If necessa .
8. NAME ADDRESS CITY AND STATE ZIP CODE

ltlt1 Zh!Jt/J flJt1U11NI l FYfS /?i~A-CH \.\ s~rrs AVE. Liu ~N C' e"'i."..t--S .
9 NAME ADDRESS CITY AND STATE
~e /4 z. /f1AU1tN/ ) o?.rY ;rlrJSSA 4f uscn:s Id:. Los. ANtt'E~cS.
_10. NUMF.ER OF VACANCIES ON THE BOARD OF DIRECTORS. IF ANY
AGENT FOR SERVICE OF PROCESS (If the agent is an Individual, the agent must reside In Cahfornra and Item 12 must be completed witll a Caldomia
address. If the agent is another corporation, the agent must have on file with the Callfomia Secretary of State a certificate pursuant to Corporations Code
sedion 1505 and Item 12 must be left blank.)
11. NAME OF AGENT FOR SERVICE OF PROCESS
ft1 AH v'A5 I--\ r\1 ;\ 26. t\ ,.V /
12. ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA, IF AN INDIVIDUAL CITV STATE ZIP CODE
lo'tSY /J?//s...51lcH ti.Sc :.S AV.. -AJJGEL6S CA c=, caz V
TYPE OF BUSINESS
14. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATIO"I CONTAINED HEREIN.
INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT. ,
MAHv'l'\St\ Mit" 26..tt/U I ft<FS1'Jx"Alr- . /2 ..z.1.or
TYPE Off PRINT NAME OF PERSON COMPLETING THE FORM TITLE DATE
Sl,200 C (REV 0512005) APPROVED BY SECRETARY OF STA TE
#:356
State of California s
Secretary of State
Statement of Information FH41325
(Domestic Stock and Agricultural Cooperative Corporations)
FEES (Filing and Disclosure): $25.00.
If this is an amendment, see Instructions.
FILED
IMPORTANT - READ INSTRUCTIONS BEFORE COMPLETING THIS FORM In the office of the Secretary of State
1. CORPORATE NAME of the State of California
MAZGANI SOCIAL SERVICES INC.
DEC-06 2016
2. CALIFORNIA CORPORATE NUMBER

C2509317 This Space for Filing Use Only
3. If there have been any changes to the Information contained in the last Statement of Information filed with the California Secretary
of State, or no statement of Information has been previously filed, this form must be completed In Its entirety.
[rJ If there has been no change in any of the information contained in the last Statement of Information filed with the California Secretary
of State, check the box and proceed to Item 17.
Com lete Addresses for the Followin (Do not abbreviate the name of the cl Items 4 and 5 cannot be P.O. Boxes.
4. STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE CITY STATE ZIP CODE
5. STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE IN CALIFORNIA, IF ANY CITY STATE ZIP CODE
6. MAILING ADDRESS OF CORPORATION, IF DIFFERENT THAN ITEM 4 CITY STATE ZIP CODE
Names and Complete Addresses of the Following Officers (The corporation must list these three officers. A comparable title for the specific
officer may be added; however, the preprinted titles on this form must not be altered.}
7. CHIEF EXECUTIVE OFFICER/ ADDRESS CITY STATE ZIP CODE
8. SECRETARY ADDRESS CITY STATE ZIP CODE
9. CHIEF FINANCIAL OFFICER/ ADDRESS CITY STATE ZIP CODE
Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one
director. Attach additional a es, if necessa
10. NAME ADDRESS CITY STATE ZIP CODE
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY:

Agent for Service of Process If the agent is an individual, the agent must reside In California and Item 15 must be completed with a California street
address, a P.O. Box address ls not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of State a
certificate ursuant to California Cor orations Code section 1505 and Item 15 must be left blank.
14. NAME OF AGENT FOR SERVICE OF PROCESS
15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA, IF AN INDMDUAL CITY STATE ZIP CODE
T of Business
16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION
17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT.
12/06/2016 STEVE HAGHANI ACCOUNTANT
DATE TYPE/PRINT NAME OF PERSON COMPLETING FORM TITLE SIGNATURE
S (R V01 13) P E Y S CR A F TATE

#:357
EXHIBIT H
PLAINTIFF'S EXHIBIT H
Case 8:17-cv-00644-CJC-KES 1i1i - Page 20 of 77 Page ID
Document 15-4 Filed 06/14/17
zrc:nn:c1JfPE1SIIB!MWllilf1t+
#:358
Send and Manage Honey Easily. All With One Card.

The ~stern Uiiionr NetSpeoor Prepaid HasterCardr
ID Verification required. Fees apply. See prepaid rack for info.
-- N;T--r.i2154 LOC 016464 DT 022817 $500.00 !>HUNDREDDOW!RS AND
NO CENTS
* 1754685681 4 *
IUll 111 IW II 111111111 WI 111111 I ~ 111

------------
PLAINTIFF'S EXHIBIT H-1
#:359
EXHIBITCASE:
I 8:17-cv00644-CJC-KES
PLAINTIFF'S EXHIBIT I
#:360
Check #=17546856814
WESTERN UNION FINANCIAL SERVICES INC, ISSUER Englowood, Colorado MONEY

P,yll>'t II w,n, FllgO Bani GiwJurioo.-..,,, NA, GRn<S.,..,_, Cd<w"'" 0 RD ER'
17-546856814
lfJ
0$SUWO/,QEHT)
NOT GOOD OVER $500
4~}~S~D 022817
175468568147 L 016464
$ c;Ao
YV II
I\/\
VV
PAV EXACTLYFIVE HUNDRED DOLLARS AND NO CENTS '

~~bl~ J~E/1. /J? Df'~'t1'J'~ >v\ . . ' PAYMENT FOR/ACCT. II
01: 10 2mo i..001: i..o 17 si.. i;.a s i;a ii.. ?11
This is a true copy from the business records of

Integrated Payment Systems.
PLAINTIFF'S EXHIBIT B-1
#:361
EXHIBIT J
PLAINTIFF'S EXHIBIT J
#:362
MAZGANI SOCIAL SERVICES

11 10 South Robertson Blvd, Suite 3
Los Angeles, CA 90035
(310) 273-5228
4/3/ 2017
lraj Khosroabadi
20508 Sherman Way, Un it A
P.O. Box 158
Canoga Pa rk, Ca 91306
Dea r M r. lraj Khosroabadi,
Th is letter is t o inform yo u t hat t his office ca nnot represent you in regards to your social securit y
benefits. It has been brought to my attention by a case worker at the local SSA office that you already
have a case pending with t he SSA and t hat you are scheduled for a consultative examination on April 20,
2017 at 11:30am.
Per you r request on the phone ea rlier today, please find enclosed a money order (Wells Fargo money
o rd er #0 85510370) refunding you t he $500.00 you paid towards the costs of your case with this office.
PLAINTIFF'S EXHIBIT J-1
Very t ruiy yours,
M ah ash M azga ni
#:363
RINTED ON LINEMARK PAPER - HOLD TO LIGHT TO VIEW. FOR ADDITIONAL SECURITY FEATURES SEE BACK.
-24
10(8)
PERSONAL MONEY ORDER 0085510370
~
aJ
MAZGANI C:
0
.!!!
'iii
April 03, 2017 .;
C
OF
:!MJ k HtJs R<Y ;JB/JD 1.. @
"C
..
'ti
::,
ed dollars and no cents*** **$500.00** u
.!:
..
e::,
.;
..
u.
, N.A. >,
;;
) 394-3122
.."
"'
o a s s o :1 ? o 11 ,: 2 o o o 2 '1 a : '1 a i; s o s :1 a i; 11
#:364
#:365
EXHIBIT K
PLAINTIFF'S EXHIBIT K
Recents #:366 Edit
o e o ~
messa... call video mail
Today
11:21 AM Incoming Call 17 seconds
work
J_(310) 273-5228
mobile RECENT CASE: 8:17-cv00644-CJC-KES

/')1/'\\ OQ') f'\f'\/11 PLAINTIFF'S EXHIBIT K-1
000
000 nn
Recents #:367 Edit
oe
Today
work
J_(310) 273-5228
mobile RECENT CASE: 8:17-cv00644-CJC-KES

000
000 nn
Recents #:368
No Caller ID

Today
PLAINTIFF'S EXHIBIT K-3
000
000 nn
Done 5 of 7
#:369
oe
Today
work RECENT
J_(310) 273-5228
mobile CASE: 8:17-cv00644-CJC-KES

-
Done 3 of 7
#:370
o e o ~
Today
10:13 AM Missed Call
work
1_(310) 273-5228
mobile CASE: 8:17-cv00644-CJC-KES

-
#:371
EXHIBIT L
PLAINTIFF'S EXHIBIT L
Case
Case8:17-cv-00644-CJC-KES
8:17-cv-00644-CJC-KESDocument
Document11-1
15-4Filed
Filed
05/03/17
06/14/17Page
Page1 34
of 7of Page
77 Page
ID #:189
ID
#:372
1 THE NEWELL LAW FIRM

FELTON T. NEWELL (SBN 201078)
2 felton@thenewelllawfirm.com
12777 W. Jefferson Blvd., Bldg. D, Ste. 300
3 Playa Vista, California 90066
Telephone: (213) 394-2617
4 Facsimile: (213) 402-7187
5 Attorneys for Defendants:
MAZGANI SOCIAL SERVICES, INC.,
6 MAHVASH MAZGANI, NAZANIN
MAZGANI, and NEYAZ MAZGANI
7
10
Telephone: (213) 394-2617 Facsimile: (213) 402-7187
11 IRAJ KHOSROABADI, and Individual Case No. 8:17-cv-00644-CJC-KES

12 Plaintiff,
v. DECLARATION OF MAHVASH
THE NEWELL LAW FIRM
MAZGANI IN SUPPORT OF
Playa Vista, CA 90066
13
MAZGANI SOCIAL SERVICES, INC., DEFENDANTS OPPOSITION
14 a California Corporation, MAHVASH TO PLAINTIFFS EX PARTE
MAZGANI, NAZANIN MAZGANI, APPLICATION FOR A
15 NEYAZ MAZGANI, and DOES 1 TEMPORARY RESTRAINING
through 25, inclusive, ORDER
16
Defendants. Hon. Cormac J. Carney
17
18
19
20
21
22
23
24
25
26
27
28 CASE: 8:17-cv00644-CJC-KES
PLAINTIFF'S EXHIBIT L-1
DECLARATION OF MAHVASH MAZGANI
165090.1
Case
Document11-1
15-4Filed
Filed
05/03/17
06/14/17Page
Page2 35
of 7of Page
77 Page
ID #:190
ID
#:373
1
DECLARATION OF MAHVASH MAZGANI
2
I, Mahvash Mazgani, declare as follows:
3
1. I am a defendant in this action.
4
2. I have personal knowledge of the facts set forth in this
5
declaration, and if called upon as a witness I could testify competently as to
6
those facts. I make this declaration in support of Defendants Opposition to
7
Plaintiffs Ex Parte Application for a Temporary Restraining Order.
8
3. In 1992, I started providing services to clients through a sole
9
proprietorship. In 2004, I incorporated my business Mazgani Social
10
Services, Inc. (the Company). Among the services the Company provides
11
are: MediCal, Medicare, in home supportive services, reentry permits,
12
citizenship, green card, retirement and assistance with Social Security
THE NEWELL LAW FIRM
13
Administration (SSA) disability benefits. Many of the Companys clients
14
are members of the regions Persian community. Before this action, I have
15
received only a handful of complaints from my clients in 25 years. I own
16
60% of the Company, which is currently located at 1110 Robertson
17
Boulevard in Los Angeles.
18
4. I have reviewed Plaintiff Iraj Khosroabadis Declaration, and it
19
contains many falsehoods.
20
5. My daughters Nazanin Mazgani and Neyaz Mazgani have no
21
role in the Companys operations. I have never simultaneously represented
22
a client with Nazanin. Neither Nazanin nor Neyaz engage in any formal or
23
informal functions as Company officers or perform work for the Company.
24
6. Only a small percentage of the Companys profits are derived
25
from clients seeking SSA benefits. This year, the Company has only
26
advised three customers who have been approved for benefits. In 2016, the
27
Company only advised seven customers who were approved for benefits
1
PLAINTIFF'S
DECLARATION OF MAHVASH MAZGANI EXHIBIT L-2
165090.1
Case
Document11-1
15-4Filed
Filed
05/03/17
06/14/17Page
Page3 36
of 7of Page
77 Page
ID #:191
ID
#:374
1
and in 2015, the Company had only four approved clients. When a client is
2
not approved for benefits, the Companys only charge is the $500 the
3
Company collects for out-of-pocket administrative costs.
4
7. For a client whose application for SSA disability benefits is
5
approved, the Companys fee varies depending on the amount of benefits.
6
In many instances, the Company has accepted less than the maximum
7
amount provided for by the applicable SSA guidelines. For the past several
8
years, fees the Company collected providing services to clients seeking SSA
9
benefits have constituted less than 10% of the Companys annual income. If
10
the Court were to seize the Companys assets, it would be devastating to me
11
as I need the Companys profits to pay my monthly bills and the
12
Companys monthly bills.
THE NEWELL LAW FIRM
13
8. Mr. Khosroabadi first contacted me in late February 2017
14
seeking assistance, he claimed, with his application with SSA disability
15
benefits. He falsely claimed that he was unemployed and homeless.
16
Because of his economic status, I told him I would charge him less than I
17
normally charge clients applying for SSA benefits. I told him he just needed
18
to pay $500 for administrative costs for my work as his SSA representative.
19
I also explained that, if Mr. Khosroabadi application for benefits was not
20
approved, he would owe no fee. I never asked Mr. Khosroabadi to give me
21
five personal checks with the pay to line left blank, and he never gave any
22
such checks to me. Moreover, I did not claim that Mr. Khosroabadi would
23
forfeit his benefits if he did not pay fees to me.
24
9. After Mr. Khosroabadi gave me a money order for $500 at my
25
office on March 1, 2017, I cashed the money order and began working on
26
his case. My SSA contact subsequently informed me that Mr. Khosroabadi
27
already had an assigned representative. Upon learning that Mr.
2
PLAINTIFF'S
165090.1
Case
Document11-1
15-4Filed
Filed
05/03/17
06/14/17Page
Page4 37
of 7of Page
77 Page
ID #:192
ID
#:375
1
Khosroabadi was already represented, I sent a check to him for $500, along
2
with a cover letter explaining that I was returning the funds as he already
3
had a case pending with the SSA. I have never personally harassed or
4
threatened Mr. Khosroabadi or his family, I have not encouraged anyone
5
else to harass or threaten Mr. Khosroabadi or his family, and I am not
6
aware that anyone she knows has harassed or threatened to harass Mr.
7
Khosroabadi or his family. Furthermore, I have never called Mr.
8
Khosroabadi and hung up the phone.
9
10. The Social Security Administration publishes guidance to
10
representatives. A true and correct copy of the guidance is attached hereto
11
as Exhibit A.
12
THE NEWELL LAW FIRM
13
I declare under penalty of perjury under the laws of the United States of
14
America that the foregoing is true and correct.
15
Executed on May 3, 2017 at Los Angeles, California
16
17 /s/ Mahvash Mazgani
18
MAHVAN MAZGANI
19
20
21
22
23
24
25
26
27
3
PLAINTIFF'S
165090.1
Case
Document11-1
15-4Filed
Filed
05/03/17
06/14/17Page
Page5 38
of 7of Page
77 Page
ID #:193
ID
#:376
1 PROOF OF SERVICE
2
4
5
6
7
United States District Court )
) ss.
8
Central District of California )
9
10 I am employed in the County of Los Angeles, State of California, I am
11
is 12777 W. Jefferson Blvd., Bldg. D, Ste. 300, Playa Vista, CA 90066.
12
THE NEWELL LAW FIRM
On this date, I served the foregoing document(s) described as:

13
14
DECLARATION OF MAHVASH MAZGANI IN SUPPORT OF
15 DEFENDANTS OPPOSITION TO PLAINTIFFS EX PARTE
APPLICATION FOR A TEMPORARY RESTRAINING ORDER
16
17 on all other parties and/or their attorney(s) of record to this action by
placing a true copy thereof in a sealed envelope, as follows:
18
19 SERVICE LIST
20
21 Robert B. Salgado, Esq. Attorneys for Plaintiff
Aperture Law Firm Iraj Khosroabadi
22
PO Box 17741
24
25 BY MAIL: By placing a true copy thereof in a sealed envelope and
addressed to the parties listed below. I placed such envelope(s) for
26
deposit in the U.S. Mail for service by the United States Postal
27 Service, with postage thereon fully prepaid.
4
DECLARATION OF MAHVASH PLAINTIFF'S
MAZGANI EXHIBIT L-5
165090.1
Case
Document11-1
15-4Filed
Filed
05/03/17
06/14/17Page
Page6 39
of 7of Page
77 Page
ID #:194
ID
#:377
1 I am readily familiar with this firms practice of collection and

2 processing correspondence for mailing. Under that practice, it
3 would be deposited with the U.S. Postal Service on that same day
with postage thereon fully prepaid at Los Angeles, California, in the
4
ordinary course of business. I am aware that, on motion of the party
5 served, service is presumed invalid if postal cancellation date or
6 postage meter date is more than one day after the date of deposit for
7
mailing in affidavit.
BY HAND DELIVERY/PERSONAL SERVICE: I caused the
8
foregoing envelope to be delivered by hand.
9 BY FACSIMILE. On this date, by facsimile transmission to the
10 parties and/or to their attorney(s) of record stated above and/or
attached list to their know business facsimile number(s).
11
BY E-MAIL. On this date, by electronic transmission (e-mail) to the

THE NEWELL LAW FIRM
attached list to their known e-mail address(es). The document(s)

13
14 was/were transmitted by electronic transmission. The transmission
was reported as complete and without error.
15
BY OVERNIGHT DELIVERY. On this date, I placed the Federal
16 Express (or other overnight couriers) package for overnight delivery
17 in a box or location regularly maintained by Federal Express (or
18 other overnight couriers) at my office or I delivered the package to
an authorized courier or driver authorized by Federal Express (or
19
other overnight couriers) to receive documents and/or packages.
20 The document(s) was/were placed in a sealed envelope or package
21 designated by Federal Express (or other overnight couriers) with
delivery fees paid or provided for, addressed to the person(s) on
22
whom it is to be served at the address(es) shown above/attached list,
23 at the office address(es) as last given by that person on any
24 document filed in the cause and served on the party making service;
25 otherwise at that partys place of residence.
BY ECF. Filed and served electronically in accordance with the
26
Courts electronic filing (ECF) rules, pursuant to which registered
27 ECF users receive service copies by e-mail delivery.
5
DECLARATION OF MAHVASH PLAINTIFF'S
MAZGANI EXHIBIT L-6
165090.1
Case
Document11-1
15-4Filed
Filed
05/03/17
06/14/17Page
Page7 40
of 7of Page
77 Page
ID #:195
ID
#:378
1 STATE: I declare under penalty of perjury under the laws of

2 the State of California that the foregoing is true and correct.
3 FEDERAL: I hereby certify that I am employed in the office of
a member of the Bar of this Court at whose direction the service was
4
made, and I certify under penalty of perjury that the foregoing is
5 true and correct.
6
7
Executed on this 3rd day of May, 2017, at Los Angeles, California.
8
9 Felton T. Newell /s/ Felton T. Newell
10 [NAME] [SIGNATURE]
11
12
THE NEWELL LAW FIRM
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
6
PLAINTIFF'S
165090.1
#:379
EXHIBIT M
PLAINTIFF'S EXHIBIT M
Case
Document11-4
15-4Filed
Filed
05/03/17
06/14/17Page
Page1 42
of 5of Page
77 Page
ID #:212
ID
#:380

Telephone: (213) 394-2617
4 Facsimile: (213) 402-7187
7
10

12 Plaintiff,
v. DECLARATION OF NEYAZ
THE NEWELL LAW FIRM
13
16
17
18
19
20
21
22
23
24
25
26
27
PLAINTIFF'S EXHIBIT M-1
DECLARATION OF NEYAZ MAZGANI
165090.1
Case
Document11-4
15-4Filed
Filed
05/03/17
06/14/17Page
Page2 43
of 5of Page
77 Page
ID #:213
ID
#:381
1
DECLARATION OF NEYAZ MAZGANI
2
I, Neyaz Mazgani, declare as follows:
3
4
5
6
7
8
3. While my sister Nazanin and I are listed as Company officers in
9
a 2005 Statement of Information the Company filed with the California
10
Secretary of States Office, neither of us engage in any formal or informal
11
functions as Company officers or perform work for the Company.
12
4. While I used to work at the Company, I have not worked there
THE NEWELL LAW FIRM
13
since 2009. Between 2008 and 2010, I worked at two law offices. From 2011-
14
2015, I worked for companies providing in home supportive services and
15
attended school. In 2014, I graduated from UC Riverside, and in 2015, I
16
started attending the University of West Los Angeles Law School, where I
17
am currently enrolled.
18
19
20
21
22
23 /s/ Neyaz Mazgani
24
NEYAZ MAZGANI
25
26
27
KHOSROABADI
1
v. MAZGANI ET AL
PLAINTIFF'S
DECLARATION EXHIBIT M-2
OF NEYAZ MAZGANI
165090.1
Case
Document11-4
15-4Filed
Filed
05/03/17
06/14/17Page
Page3 44
of 5of Page
77 Page
ID #:214
ID
#:382
1 PROOF OF SERVICE
2
4
5
6
7
) ss.
8
9
11
12
THE NEWELL LAW FIRM

13
14
DECLARATION OF NEYAZ MAZGANI IN SUPPORT OF
16
18
19 SERVICE LIST
20
22
PO Box 17741
24
26
KHOSROABADI
2
v. MAZGANI ET AL
DECLARATIONPLAINTIFF'S EXHIBIT M-3
OF NEYAZ MAZGANI
165090.1
Case
Document11-4
15-4Filed
Filed
05/03/17
06/14/17Page
Page4 45
of 5of Page
77 Page
ID #:215
ID
#:383

4
7
8
11

THE NEWELL LAW FIRM

13
15
19
22
26
KHOSROABADI
3
v. MAZGANI ET AL
PLAINTIFF'S
OF NEYAZ MAZGANI
165090.1
Case
Document11-4
15-4Filed
Filed
05/03/17
06/14/17Page
Page5 46
of 5of Page
77 Page
ID #:216
ID
#:384

4
5 true and correct.
6
7
Executed on this 3rd day of May, 2017, at Los Angeles, California.
8
11
12
THE NEWELL LAW FIRM
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
KHOSROABADI
4
v. MAZGANI ET AL
PLAINTIFF'S
OF NEYAZ MAZGANI
165090.1
#:385
EXHIBIT N
PLAINTIFF'S EXHIBIT N
Case
Document11-3
15-4Filed
Filed
05/03/17
06/14/17Page
Page1 48
of 6of Page
77 Page
ID #:206
ID
#:386

Telephone: (213) 394-2617
4 Facsimile: (213) 402-7187
7
10

12 Plaintiff,
v. DECLARATION OF NAZANIN
THE NEWELL LAW FIRM
13
16
17
18
19
20
21
22
23
24
25
26
27
PLAINTIFF'S EXHIBIT N-1
DECLARATION OF NAZANIN MAZGANI
165090.1
Case
Document11-3
15-4Filed
Filed
05/03/17
06/14/17Page
Page2 49
of 6of Page
77 Page
ID #:207
ID
#:387
1
DECLARATION OF NAZANIN MAZGANI
2
I, Nazanin Mazgani, declare as follows:
3
4
5
6
7
8
3. While my sister Neyaz and I were listed as Company officers in
9
a 2005 Statement of Information the Company filed with the California
10
Secretary of States Office, neither of us engage in any formal or informal
11
functions as Company officers or perform work for the Company. I have
12
no role in the Companys operations.
THE NEWELL LAW FIRM
13
4. I am a 2009 graduate of the John F. Kennedy School of Law and
14
I have been a member of the California Bar since 2010. In July 2013, I
15
founded the Law Offices of Nazanin Mazgani (the Mazgani Firm),
16
located at 11400 West Olympic Boulevard in Los Angeles. The Mazgani
17
Firms website accurately identifies the five practice areas in which I
18
specialize: immigration, Social Security Disability and SSI, personal injury,
19
surplus funds collection offers and trustee sale.
20
5. While my mother only advises SSI clients applying for disability
21
benefits, the vast majority of my Social Security practice involves advising
22
clients who have been denied SSA benefits and seek to have that decision
23
reversed in a hearing before an administration law judge. My mother and I
24
have never simultaneously represented a client.
25
6. While I was in law school, I received a scholarship from the
26
Contra Costa Bar Association and participated in the Bay Area Legal
27
Immigrant Project. As a practicing attorney, I have volunteered my time
1
PLAINTIFF'S
DECLARATION OF NAZANIN EXHIBIT N-2
MAZGANI
165090.1
Case
Document11-3
15-4Filed
Filed
05/03/17
06/14/17Page
Page3 50
of 6of Page
77 Page
ID #:208
ID
#:388
1
and expertise at the Esperanza Immigration Rights Project.
2
3
4
5
6
7 /s/ Nazanin Mazgani
8
NAZANIN MAZGANI
9
10
11
12
THE NEWELL LAW FIRM
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
2
PLAINTIFF'S
DECLARATION OF NAZANIN MAZGANIEXHIBIT N-3
165090.1
Case
Document11-3
15-4Filed
Filed
05/03/17
06/14/17Page
Page4 51
of 6of Page
77 Page
ID #:209
ID
#:389
1 PROOF OF SERVICE
2
4
5
6
7
) ss.
8
9
11
12
THE NEWELL LAW FIRM

13
14
DECLARATION OF NAZANIN MAZGANI IN SUPPORT OF
16
18
19 SERVICE LIST
20
22
PO Box 17741
24
26
3
PLAINTIFF'S
DECLARATION OF NAZANIN EXHIBIT N-4
MAZGANI
165090.1
Case
Document11-3
15-4Filed
Filed
05/03/17
06/14/17Page
Page5 52
of 6of Page
77 Page
ID #:210
ID
#:390

4
7
8
11

THE NEWELL LAW FIRM

13
15
19
22
26
4
PLAINTIFF'S
165090.1
Case
Document11-3
15-4Filed
Filed
05/03/17
06/14/17Page
Page6 53
of 6of Page
77 Page
ID #:211
ID
#:391

4
5 true and correct.
6
7 Executed on this 3rd day of May 2017, at Los Angeles, California.
8
11
12
THE NEWELL LAW FIRM
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
5
PLAINTIFF'S
165090.1
#:392
EXHIBIT O
PLAINTIFF'S EXHIBIT O
COMPLETING THIS FORM TO #:393APPOINT A REPRESENTATIVE
Choosing to be Represented How to Complete this Form
You can choose to have a representative help you when Please print or type your answers on this form. At the top
you do business with Social Security. We will work with of the form, provide your full name and your Social
your representative, just as we would with you. It is Security number. If your claim is based on another
important that you select a qualified person because, once person's work and earnings, also provide the "wage
appointed, your representative may act for you in most earner's" name and Social Security number. If you
Social Security matters. We give more information, and appoint more than one individual as your representative,
examples of what a representative may do, in the section you may want to complete a form for each of them.
titled "Information for Claimants."
Part i Claimant's Appointment of Representative
Give the name and address of the individual(s) you are
Privacy Act Statement appointing. You may appoint an attorney or any other
Collection and Use of Personal Information qualified individual to represent you. You also may appoint
more than one individual, but please refer to the
Sections 206(a) and 1631 (d) of the Social Security Act, "Information for Claimants" section "What your
as amended, authorize us to collect this information. We Representative(s) May Charge" for more information
will use the information you provide on this form to verify about payment of fees. You can appoint one or more
your appointment of an individual as your representative individuals in a firm, corporation, or other organization as
and his or her acceptance of the appointment. your representative(s), but you may not appoint a law firm,
Furnishing us this information is voluntary. However, if legal aid group, corporation or organization itself.
you want to use this form to appoint someone to act on
your behalf in matters before the Social Security Check the block(s) showing the program(s) under which
Administration (SSA), then you and that individual must you have a claim. You may check more than one block.
complete the appropriate sections of this form. Check:
We rarely use the information you supply for any purpose
other than to verify your appointment of an individual as Title II (RSDI), if your claim concerns retirement,
your representative and his or her acceptance of the survivors, or disability insurance benefits.
appointment. However, we may use the information for Title XVI (SSI), if your claim concerns Supplemental
the administration of our programs including sharing Security Income.
Title XVIII (Medicare Coverage), if your claim concerns
information:
entitlement to Medicare or enrollment in the
Supplementary Medical Insurance (SMI) plan.
1. To comply with Federal laws requiring the Title VIII (SVB), if your claim concerns entitlement to
release of information from our records Special Veterans Benefits.
(e.g., to the Government Accountability Office
and Department of Veterans Affairs); and, When you give your permission your representative may
designate an associate (e.g. a clerk), or other party or
2. To facilitate statistical research, audit, or entity (e.g. a copying service) to receive information from
investigative activities necessary to assure the your claim file on your representative's behalf for the
integrity and improvement of our programs duration of your claim. If you want to give your
(eg., to the Bureau of the Census and to representative permission to do that, check the block to
private entities under contract with us). authorize this release.
A complete list of when we may share your information If you will have more than one representative, check the
with others, called routine uses, is available in our Privacy appropriate block and give the name of the individual you
Act System of Records Notice entitled, Appointed want to be your principal representative. SSA will make
Representative File, 60-0325. Additional information contacts with, and send notices or requests for
about this and other system of records notices and our development to, only the principal representative. The
programs are available from our Internet website at principal representative will provide copies of notices or
www.socialsecurity.gov or at your local Social Security requests to other co-representatives.
office. We may share the information you provide to other
health agencies through computer matching programs. You must sign and date the form. Print or type your
Matching programs compare our records with records address, area code and telephone number.
kept by other Federal, State, or local government
agencies. We use the information from these programs to If you are appointing a representative to replace a
establish or verify a person's eligibility for federally funded representative that you discharged or who withdrew his or
or administered benefit programs and for repayment of her representation, you must notify us in writing that the
incorrect payments or delinquent debts under these prior appointment has ended.
programs.
Form SSA-1696-U4 (07-2014) ef (07-2014) KHOSROABADI v. MAZGANI ET AL
Use Prior Editions Until Exhausted
PLAINTIFF'S EXHIBIT O-1
Part II Representative's Acceptance of Appointment#:394
Each individual you appoint in Part I should also complete
Part II. If the individual is not an attorney, he or she must
give his or her name, state that he or she accepts the
appointment, and sign the form.
Part Ill Fee Arrangement

To help in processing benefits and fee payments timely
you and your representative should complete this section.
Your representative should check a box, sign and date the
form. Your representative may choose to receive
payment, waive direct payment, or waive payment of the
fee altogether. If you and your representative change your
arrangement before we decide your claim, you can
provide a new or amended form so that we can update our
records. If you appoint a second representative or co-
counsel who also will not charge a fee, he or she should
also complete this part or provide a new form, or if not
using the form, give us a separate, written waiver
statement. If your representative is not eligible for direct
payment, or is an attorney or an eligible non-attorney who
waives direct payment, you will be responsible for paying
any fee we authorize.
Under certain circumstances, we do not have to authorize

the fee. These circumstances include where a Court has
awarded a fee based on your representative's actions as
a legal guardian or court-appointed representative, or
where a business (such as an insurance company), other
organization or government agency will pay your
representative's fee and you and your beneficiaries have
no liability to pay any fees or expenses.
Paperwork Reduction Act Statement - This information

collection meets the requirements of 44 U.S.C. 3507, as
amended by Section 2 of the Paperwork Reduction Act of
1995. You do not need to answer these questions unless
we display a valid Office of Management and Budget
control number. We estimate that it will take about 10
minutes to read the instructions, gather the facts, and
~nswer the questions. SEND THE COMPLETED FORM
. J YOUR LOCAL SOCIAL SECURITY OFFICE. The
office is listed under U. S. Government agencies in
your telephone directory or you may call Social
Security at 1-800-772-1213 (TTY 1-800-325-0778). You
may send comments on our time estimate above to: SSA,
6401 Security Blvd, Baltimore, MD 21235-6401. Send
only comments relating to our time estimate to this
address, not the completed form.
References
18 U.S.C. 203,205, and 207; and 42 U.S.
C. 406 (a), 1320a-6, and 1383(d)(2)
20 CFR 404.1700 et. seq., 408.1101, and
416.1500 et. seq.
Social Security Rulings 83-27 and 82-39
26 U.S.C. 6041 and 6045(1)
#:395REPRESENTATIVES
INFORMATION FOR
Fees for Representation Fee Agreement Process

An attorney or other individual who wants to charge or If you and the claimant have a written fee agreement, one
collect a fee for providing services in connection with a of you must give it to us before we decide the claim(s). We
claim before the Social Security Administration (SSA) usually will approve the agreement if:
must generally obtain our prior authorization of the fee for
representation. The only exceptions are if: you both signed it;
the fee you agreed on is no more than 25 percent of
certain requirements are met and a third-party entity, past-due benefits, or $6,000 (or a higher amount we
such as a business, an insurance carrier, a for profit, set and announce in the Federal Register), whichever
or nonprofit organization or a government agency will is less;
pay the fee and any expenses from its own funds and we approve the claim(s); and
the claimant and auxiliary beneficiaries incur no liability,
the claim results in past-due benefits.
directly or indirectly, for the cost(s); or
a Federal court awarded a fee based on the We will send you a copy of the notice we send the
representative's activities as the claimant's legal guardian claimant telling him or her the amount of the fee you can
or court-appointed representative; charge based on the agreement.
a Federal court awarded a fee for representational If we do not approve the fee agreement, we will tell you in
services provided before the court. In those cases, writing. We also will tell you and the claimant that you
neither the Federal court nor SSA can authorize a fee for must file a fee petition if you wish to charge and collect a
the other. fee.
Obtaining Authorization of a Fee After we tell you the amount of the fee you can charge,
To charge a fee for services, you must use one of two you or the claimant may ask us in writing to review the
mutually exclusive fee authorization processes. You must
authorized fee. If we approved a fee agreement, the
file either a fee petition or a fee agreement with us. In person who decided the claim(s) also may ask us to lower
either case, you cannot charge more than the fee amount the amount. Someone who did not decide the amount of
we authorize. the fee the first time will review and finally decide the
amount of the fee.
Fee Petition Process
You may file a fee petition after you complete your Collecting a Fee
services to the claimant. This written request must You may accept money for your fee in advance, as long
describe in detail the amount of time you spent on each as you hold it in a trust or escrow account. The claimant
service provided and the amount of the fee you are never owes you more than the fee we authorize, except
requesting. In order to directly pay you under a fee
for:
petition, you must either file a fee petition or notify us
any fee a Federal court allows for your services
within 60 days after we decide the claim of your intent to
before it; and
file a fee petition.
out-of-pocket expenses you incur or expect to incur, for
)U must give the claimant a copy of the fee petition and example, the cost of getting evidence. Our authorization
each attachment. The claimant may disagree with the is not needed for such expenses.
information shown by contacting a Social Security office
If you are not an attorney and you are ineligible to receive
within 20 days of receiving his or her copy of the fee
direct payment, you must collect the authorized fee from
petition. We will consider the reasonable value of the
the claimant. If you are interested in becoming eligible to
services provided, and send you notice of the amount of
receive direct payment, you can find more information
the fee you can charge.
about this on our "Representing Social Security
Claimants" website:
b.l1p: I IW:N'#. ss a.g Q>'LC@ rese nta tio n/.
If you are an attorney or a non-attorney whom SSA has#:396 References
found eligible to receive direct payment and you register
18 U.S.C. 203,205, and 207; and 42 U.S.C. 406
with SSA as described below, we usually withhold 25
(a), 1320a-6, and 1383(d)(2)
percent of any past-due benefits that result from a
favorably decided retirement, survivors, disability 20 CFR 404.1700 et. seq., 408.1101, and
insurance, or supplemental security income claim. Once 416.1500 et. seq.
we authorize a fee, we pay you all or part of the fee from Social Security Rulings 83-27 and 82-39
the funds withheld. We will also charge you the
26 U.S.C. 6041 and 6045(f)
assessment required by section 206(d) and 1631(d)(2)(C)
of the Social Security Act. You cannot charge or collect
this expense from the claimant. You will need to collect
from the claimant:
the rest of the fee he or she owes, if the amount of the

authorized fee is more than the amount of money we
withheld and paid you for the claimant, plus any amount
you held for the claimant in a trust or escrow account.
all of the fee he or she owes, if we did not withhold

past-due benefits, (for example, because there are no
past-due benefits; you waived direct payment or did
not register for direct payment; the claimant discharged
you or you withdrew from representing before we issued
a favorable decision); or we withheld past-due benefits,
but you did not ask us to authorize a fee or tell us that
you planned to ask for a fee within 60 days after the date
of the notice of award and we released the withheld
amount to the claimant.
Registering for Direct Fee Payment

If you are eligible and want to receive direct payment, you
must register with us before we effectuate a favorable
decision on the claim. To register, you must submit a
Form SSA-1699 (Registration of Individuals and Staff for
Appointed Representative Services) once and a Form
SSA-1695 (Identifying Information for Possible Direct
Payment of Authorized Fees) with each appointment. We
will use the information you provide on these forms to
issue you a Form 1099-MISC if we pay you aggregate
fees of $600 or more in a calendar year. The Internal
Revenue Code requires that we do this. For information
on the registration process, see our "Representing Social
curity Claimants" website
http://www.ssa.gov/representation/.
Conflict of Interest and Penalties

If you commit improper acts, you can be suspended or
disqualified from representing anyone before SSA. You
also can face criminal prosecution. Improper acts include:
If you are or were an officer or employee of the United

States, providing services as a representative in certain
claims against and other matters affecting the Federal
government.
Knowingly and willingly furnishing false information.
Charging or collecting an unauthorized fee, or charging
or collecting too much for services provided in any claim,
including services before a court that made a favorable
decision.
Social Security Administration #:397 Form Approved
Please read the instructions before completing this form. 0MB No. 0960-0527
Name (Claimant) (Print or Type) Social Security Number
Wage Earner (If Different) Social Security Number
Part I CLAIMANT'S APPOINTMENT OF REPRESENTATIVE

I appoint this i n d i v i d u a l ' - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
{Name and Address)
to act as my representative in connection with my claim(s) or asserted right(s) under:
D Title II (RSDI) D Title XVI (SSI) D Title XVIII (Medicare) D Title VIII (SVB)
This individual may, entirely in my place, make any request or give any notice; give or draw out evidence or
information; get information; and receive any notice in connection with my pending claim(s) or asserted right(s).
D I authorize the Social Security Administration to release information about my pending claim(s) or asserted
right(s) to designated associates who perform administrative duties (e.g. clerks), partners, and/or parties
under contractual arrangements (e.g. copying services) for or with my representative.
D I appoint, or I now have, more than one representative. My principal representative is:
(Name of Principal Representative)

Signature (Claimant) Address
Telephone Number (with Area Code) Fax Num Date
Part II REPRESENTATIVE'S ACCEPTANCE OF APPOINTMENT

I, , hereby accept the above appointment. I certify that I
have not been suspended or prohibited from practice before the Social Security Administration; that I am not
disqualified from representing the claimant as a current or former officer or employee of the United States; and
that I will not charge or collect any fee for the representation, even if a third party will pay the fee, unless it has
been approved in accordance with the laws and rules referred to on the reverse side of the representative's
copy of this form. If I decide not to charge or collect a fee for the representation, I will notify the Social Security
Administration. (Completion of Part Ill satisfies this requirement.)
Check one: DI am an attorney. DI am a non-attorney eligible for direct payment under SSA law.
D I am a non-attorney not eligible for direct payment.
I am now or have previously been disbarred or suspended from a court or bar to which I was previously
admitted to practice as an attorney. DYES D NO
I am now or have previously been disqualified from participating in or appearing before a Federal program or agency.
DYES D NO
I declare under penalty of perjury that I have examined all the information on this form, and on any accompanying
statements or fonns, and it is true and correct to the best of my knowledge.
Signature (Representative) Address
i elephone Number (with Area Code) Fax Number (with Area Code) Date
Part Ill FEE ARRANGEMENT

(Select an option, sign and date this section.)
D I am charging a fee and requesting direct payment of the fee from withheld past-due benefits. (SSA must authorize the
fee unless a regulatory exception applies.)
D I am charging a fee but waiving direct payment of the fee from withheld past-due benefits -I do not qualify for or do not
request direct payment. (SSA m.tJ.fil authorize the fee unless a regulatory exception applies.)
D I am waiving fees and expenses from the claimant and any auxiliary beneficiaries --By checking this block I certify
that my fee will be paid by a third-party entity or government agency, and that the claimant and any auxiliary beneficiaries
are free of all liability, directly or indirectly, in whole or in part, to pay any fee or expenses to me or anyone as a result of
their claim(s) or asserted right(s). (SSA does not need to authorize the fee if a third-party entity or a government agency will pay from
its funds the fee and any expenses for this appointment. Do not check this block if a third-party individual will pay the fee.)
D I am waiving fees from any source --1 am waiving my right to charge and collect any fee, under sections 206 and 1631
(d)(2) of the Social Security Act. I release my client and any auxiliary beneficiaries from any obligations, contractual or
otherwise, which may be owed to me for services provided in connection with their claim(s) or asserted right(s).
Signature (Representative) 1Date
Form SSA-1696-U4 (07-2014) ef (07-2014)
I h:i:> Prinr l=rlitinnc;i; I Inti! l=vh,:rndi:>ri FILE COPY
Name (Claimant) (Print or Type) ocial Security Number

I appoint this individual,
----------------------------------
(Name and Address)
D Title ll(RSDI) D Title XVI (SSI) D Title XVIII (Medicare) D Title VIII (SVB)
DI appoint, or I now have, more than one representative. My principal representative is:
(Name of Principal Representative)

Telephone Number (with Area Code) Fax Number (with Area ode) Date

Check one: D I am an attorney. D I am a non-attorney eligible for direct payment under SSA law.
DYES ONO
statements or forms, and it is true and correct to the best of my knowledge.
TelephoneNumoer (with Area Code) Fax Number (with Area Code) Date
Part JII FEE ARRANGEMENT

request direct payment. (SSA must authorize the fee unless a regulatory exception applies.)
D I am waiving fees and expenses from the claimant and any auxiliary beneficiaries -By checking this block I certify
their claim(s) or asserted right(s). (SSA does not need to authorize the fee if a thirdMparty entity ora government agency will pay from
its funds the fee and any expenses for this appointment. Do not check this block if a thirdMparty individual will pay the fee.)
D I am waiving fees from any source -I am waiving my right to charge and collect any fee, under sections 206 and 1631
Signature (Representative) 1oate CASE: 8:17-cv00644-CJC-KES
Form SSA-1696-U4 (07-2014) ef (07-2014)
If,-.-. Dri ... r c:..ia;,.,,.,,. I J,..+;i C:vh..,,,,..,,...i
CLAIMANT COPY
#:399
INFORMATION FOR CLAIMANTS
What Your Representative(s) May Do Filing A Fee Agreement
We will work directly with your appointed representative If you and your representative have a written fee
unless he or she asks us to work directly with you. Your agreement, one of you must give it to us before we decide
representative may: your claim(s). We usually will approve the agreement if:
get information from your claim(s) file; you both signed it;
with your permission, designate associates who perform the fee you agreed on is no more than 25 percent of
administrative duties (e.g. clerks), partners and/or parties past-due benefits, or $6,000 (or a higher amount we set
under contractual arrangements (e.g., copying services) and announced in the Federal Register), whichever
to receive information from us on his or her behalf (by is less;
checking the appropriate block and signing this form, you we approve your claim(s); and
are providing your permission for your representative to your claim results in past-due benefits.
designate such associates, partners, and/or We will tell you in writing the amount of the fee your
contractual parties); representative can charge based on the agreement.
give us evidence or information to support your claim;
If we do not approve the fee agreement, we will tell you
come with you, or for you, to any interview, conference, and your representative in writing. If your representative
or hearing you have with us; wishes to charge and collect a fee, he or she must file a
request a reconsideration, a hearing, or Appeals Council fee petition.
review; and
help you and your witnesses prepare for a hearing and After we tell you the amount of the fee your representative
question any witnesses. can charge, you or your representative can ask us to look
at it again if either or both of you disagree with the
Also, your representative will receive a copy of the amount. If we approved a fee agreement, the person who
decision(s) we make on your claim(s). We will rely on your decided your claim(s) also may ask us to lower the
representative to tell you about the status of your claim(s), amount. Someone who did not decide the amount of the
but you still may call or visit us for information. fee the first time will review and finally decide the amount
You and your representative(s) are responsible for giving of the fee.
Social Security accurate information. It is wrong to How Much You Pay
knowingly and willingly furnish false information. Doing so
may result in criminal prosecution. You never owe more than the fee we authorize, except for:
any fee a Federal court allows for your representative's
We usually continue to work with your representative until services before it; and
(1) you notify us in writing that he or she no longer out-of-pocket expenses your representative incurs or
represents you; or (2) your representative tells us that he expects to incur, for example, the cost of getting your
or she is withdrawing or indicates that his or her services doctor's or hospital's records. Our authorization is not
have ended (for example, by filing a fee petition or not needed for such expenses.
pursuing an appeal). We do not continue to work with
someone who is suspended or disqualified from Your representative may accept money in advance as
representing claimants. We will inform"you if we suspend long as he or she holds it in a trust or escrow account.
your representative. We usually withhold 25 percent of your past-due benefits
to pay toward the fee for you if:
What Your Representative(s) May Charge your retirement, survivors, disability insurance, and/or
Each representative you appoint can ask for a fee. To supplemental security income claim(s) results in past-
charge you a fee for services, your representative must due benefits;
get our authorization if you or another individual will pay
the fee. However, as described in "Completing this form to your representative is an attorney or a non-attorney
appoint a representative, Part Ill Fee Arrangement" whom we have determined to be eligible to receive direct
section of this form, under certain circumstances, we do payment of fees; and
: have to authorize the representative's fee. To request your representative registers with us for direct payment
a fee, your representative must file a fee agreement or a before we effectuate a favorable decision on your claim.
fee petition. In either case, your representative cannot
charge you more than the fee amount we authorize. If he You must pay your representative directly:
or she does, promptly report this to your Social Security the rest of the fee you owe, if the amount of the
office. authorized fee is more than the money we withheld and
Filing A Fee Petition paid to your representative for you plus any amount your
Your representative may file a fee petition when his or her representative held for you in a trust or escrow account.
work on your claim(s) is complete. This written request
describes in detail the amount of time your representative all of the fee you owe, if we did not withhold past-due
spent on each service he or she provided you. The benefits, (for example, because there are no past-due
request also gives the amount of the fee the benefits; your representative waived direct payment, did
representative wants to charge for these services. Your not register for direct payment, you discharged the
representative must give you a copy of the fee petition and representative, or he or she withdrew from representing
each attachment. If you disagree with the information you, before we issued a favorable decision); or we
shown in the fee petition, contact your Social Security withheld an amount from your past-due benefits, but your
office. Please do this within 20 days of receiving your copy representative did not ask us to authorize a fee or tell us
of the petition. that he or she planned to ask for a fee within 60 days
after the date of your notice of award and we released
We will review the petition and consider the reasonable the withheld amount to you.
value of the services provided. Then we will tell you in
writing the amount of the fee we authorize.

I appoint this individual,
--------------------------------
(Name and Address)
OTitle II (RSDI) D Title XVI (SSI) D Title XVIII (Medicare) D Title VIII (SVB)
right(s) to designated associates who perform administrative duties (e.g. clerks}, partners, and/or parties
{Name of Principal Representative)

Telephone Number (with Area Code) Fax Number (with Area Co e) Date

DYES ONO
Telephone Nuni6er (with Area Code) Fax Number (with Area Code) Date

O I am charging a fee and requesting direct payment of the fee from withheld past-due benefits. (SSA must authorize the
O I am charging a fee but waiving direct payment of the fee from withheld past-due benefits -I do not qualify for or do not
O I am waiving fees and expenses from the claimant and any auxiliary beneficiaries -By checking this block I certify
are free of all liability, directly or indirectly, in whole or in part, to pay any fee or expenses to rne or anyone as a result of
their claim(s) or asserted right(s). (SSA does not need lo authorize the fee if a third-party entity or a government agency wifl pay from
its funds the fee and any expenses for this appointment. Do not check this block if a third-parly individual will pay the fee.)
O I am waiving fees from any source -I am waiving my right to charge and collect any fee, under sections 206 and 1631
Signature (Representative) 1oate CASE: 8:17-cv00644-CJC-KES
Form SSA-1696-U4 (07-2014) ef (07-2014)
I 1-- n.:- t:::..1:..:--- I 1-:t t:::,,._,_,,_._..I
REPRESENTATIVE COPY

I appoint this individual, - - - - - - - - - - - - - - - - - , - - - - - - - - - - - - - -
{Name and Address)
0Title II (RSDI) 0 Title XVI (SSI) 0 Title XVIII (Medicare) 0 Title VIII (SVB)
{Name of Princ!pal Representative)
Telephone Number (with Area Code) Fax Number (wit Date

DYES D NO
Telephone Number (with Area Code) Fax Number (with Area Code) Date

D I am waiving fees and expenses from the claimant and any auxiliary beneficiaries -By checking this block I certify
their claim(s) or asserted right(s). (SSA does not need to authorize the fee if a thirci-party entity or a government agency will pay from
its funds the fee and any expenses for this appointment. Do not check this block if a thirci-party individual will pay the fee.)
D I am waiving fees from any source-I am waiving my right to charge and collect any fee, under sections 206 and 1631
Signature (Representative) 1Date CASE: 8:17-cv00644-CJC-KES
Form SSA-1696-U4 (07-2014) ef (07-2014)
', __ ,,_, __ ,..._,,., ___ '-~" ....... -.. -~--'
ODARCOPY
#:402
EXHIBIT P
PLAINTIFF'S EXHIBIT P
#:403
EXHIBIT Q
PLAINTIFF'S EXHIBIT Q
#:404
EXHIBIT R
PLAINTIFF'S EXHIBIT R
#:405
EXHIBIT S
PLAINTIFF'S EXHIBIT S
1
'
NAZANIN MAZGANI (SBN270258)
LAW OFFICES OF NAZANIN MAzGANI

#:406
.
,=~Fmaa_,n,rGtaeq.)per
11400 W Olympic Blvd, J AmOtlnt recoverablt pufllllftt to GC 11897
2 Suite 200 Plus a one time admiRillirdue fN upo1
Los Angeles, California 90064 "'lrtv becomes ajtldgment nc1or /t'JI' cJ
3 Phone: (310) 892-0820
- FILED \V\oo', I
Superior Court of CaHfomla

Email: mazganilaw@gmail.com Countv of toi; Anooles
4
7 SUPERIOR COURT FOR THE STATE OF CALIFORNIA

8 COUNTY OF LOS ANGELES - CENTRAL DISTRICT
9 MAHVASH MAZGANI, an individual Case No.: BC658766
10 Plaintiff CROSSDEFENDANTSMAHVASH
MAZGANI, NEYAZ MAZGANI, NAZANIN
11 vs. MAZGANI, SHOHREH SHARIFZADEH,
HOUMAN MOGHADDAM, aka KEVIN AND MAZGANI SOCIAL SERVICES INC.,
12 MODA, an individual, MARCOS ALONZO, an NOTICE OF MOTION AND MOTION TO
individual and DOES 1-10 STRIKE ENTIRE CROSS COMPLAINT,
13 DAMAGES, AND PUNITIVE DAMAGES;
Defendants DECLARATION OF NEYAZ MAZGANI
14
15
16 MARCOS ALONZO, an individual, Date: July 26, 2017

Time: 8:30 a.m.
17 Cross Complainant, Dept: 32
18 vs. RES ID: 170525222046
19 MAHVASH MAZGANI, an individual,

NEYAZ MAZGANI, an individual,
20 NAZANIN MAZGANI, an individual,
SHOHREH SHARIFZADEH, an individual,
21 MAZGANI SOCIAL SERVICES, INC, a
corporation, , an individual and DOES 1-10,
:;r:, .,, 0 ;:u
22 inclusive, rr, l> l> rr,
n-::: -in
m::::: mm
..... m ....
23 <:Z"l)-0
,:,(")(")(")rr,-1:C,-I
Cross Defendants :b- :::c :r, ::c O
;:o :c, tJ) m
....
o #
24 b z:::c n
G)A .f:tt
IT1 ...... 1=:t ('":I
(t~ _. ... ,:.." n
,.}"I
25 TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD: ,_rr ~ "2:~ f
. ........o (.,o-,
,............
,.)
26 NOTICE IS HEREBY GIVEN that on July 26, 2017, at 8:30a.m., whicli~he

''" 0
,.,.,,) ,::,
-~,)
,..... 27 first available date under the Court Reservation System, or as soon ther,after as the ~tf8r
:..
.....
...... J
1 ~ ~
28 CROSS DEFENDANTS MAHVASH MAWANI. NEYAZ MAWANI. NAZANIN MAWANI. SH lSDRIF~H. AND
MAWANI SOCIAL SERVICES, INC, A CALIFORNIA CORPORATION'S NOTICE OF MOTIO~;MQJION;rjoSTRIKE
ENTIRE CROSS COMPLAINT, AND DAMAGES AND PUNITIVE DAMAGES FROM CROSS eo~LAfNT
PLAINTIFF'S EXHIBIT S-1

#:407
Ivan W. Halperin, Esq. (SBN 052450)

1 The Halperin Law Offices
2 1007 West 24th Street
FILED
Superior Court of Califom ia
Los Angeles, California 90007 County of Los Angeles
3
IWHalperin@Halperin.com
4 T: (310) 773-3494 (310) 861-8619
MAY 3 1 2016
5 Sherri>~:fbve Ollicer/Clerk
Attorney for Plaintiffs THE WESSON TRUST By , Ocput~
6 lshayla Chambers
and NAZANIN MAZGANI and NEYAZ
7 MAZGANI, individually and as the Trustees
of THE WESSON TRUST and MAHVASH
8
MAZGANI, individually. ~ \~ furffiru
9
1
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 IN AND FOR THE COUNTY OF LOS ANGELES

12
CENTRAL DISTRICT-STANLEY MOSK COURTHOUSE
13
14
15 BC s 2 211 7
NAZANIN MAZGANI and NEYAZ Case No.
16 MAZGANI, individually and as the
17 Trustees of the WESSON TRUST, and COMPLAINT FOR:
MAHV ASH MAZGANI, individually,
18 1. QUIET TITLE (Against all
19 Plaintiffs, Defendants);
2. DECLARATORY RELIEF
20
vs. (Against all Defendants);
21 3. SLANDER OF TITLE (Against
22 HOUMAN MOGHADDAM a/k/a all Defendants);
KEVIN MODA, an individual, and 4. CANCELLATION OF
23 DOES 1 - 100 inclusive, WRITTEN INSTRU~~~S
24 (Against all Defenda,Qjti)~ !;! . S
25
Defendants. 5. INTENTION~~~~no .._
OF EMOT~ff~Dls~ssr ~
26 ~. a ;:r::' tit
an d !1'1 ,1:,. c:, r-.
:;:p
,.\1
27 6. DEFAMATION (Again!} in R
8 ~ ~
''"r
.V,)
-r
Defendants. ~i:
28
"~
.',.,)
q)
ByFaN
..,.:,. ..
0 -o
,:ri --1-- ,l,.
,;t..
tc, o l.11
COMPLAINT C, C, :-, r-.
c:, o a a
PLAINTIFF'S EXHIBIT S-2
#:408
EXHIBIT T
PLAINTIFF'S EXHIBIT T
#:409
EXHIBIT U
PLAINTIFF'S EXHIBIT U
#:410
PLAINTIFF'S EXHIBIT U-1
#:411
PLAINTIFF'S EXHIBIT U-2
#:412
EXHIBIT V
PLAINTIFF'S EXHIBIT V
#:413
PLAINTIFF'S EXHIBIT V-1
#:414
-, :01:;
TRAl TION NO YES
~.(~t--_ ~ 'l_c'c,(o e,,"2~

r~-" ,:.~-:='I::..~~, !\.7CR
-- .
I !- _ \7
I -"-~'-
-'-,--'.:a..:--- ~---
~,:... ._~ ... ....ec'.... :--.:,..:..,.
L.... '-- ,.o.....
.......,_ ... - . .e,.. O ..-=". - rr-
... r;i_:,. ~~-...: ___ ,._--,~c,r..;c r--
.... , ""t::,,) V4. - ~ , . "--- 2 --
--:------
,. -....,~---~ -')( ~
(.-/i.r.r
.... ..._t_:>""1<0~~,:.~
.. _ _ _
-
..,,:
~o,,.; ..,.c: ."l.
I
.... . ,.-.
~
U?:~%XL--
. .: - ---_-\_,_
r:,-,~ ----,--,-".-, . . --~-;- -'"-~ -~ .,: .. ~ . .

- ... ~ --\..: :-~ ~~--- .... I.It.: ~ ... - - - - - -' - - :,
~::.,._0T-.:a
.. ::-.....--
.. ~..,
..... - ~ ... .u. . - I..3-:-
..... _ ... ""'-_ ... ____ _____ ____ __________ ___ ___ ___ D,-..
---... ...\(a-:....;,-- -
e:bot.~ "hJ rbe a.:kno'I\ ledgement w::i.s not obtline-d:

('1: .._ .. _.:;,,~:
c ............. _ ... .....
D O:..,... R-- ,u- o- Co""-"r,

.......... '--'-,; ...a ~ ... .i....L.:.
PLAINTIFF'S EXHIBIT V-2
#:415
EXHIBIT W
PLAINTIFF'S EXHIBIT W

And DOES 1 Through 25, Inclusive,: Plaintiff'S First Amended Complaint

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

And DOES 1 Through 25, Inclusive,: Plaintiff'S First Amended Complaint

Uploaded by

Copyright:

Available Formats

Case 8:17-cv-00644-CJC-KES Document 15 Filed 06/14/17 Page 1 of 53 Page ID #:279

1 Aperture Law Firm

11 CENTRAL DISTRICT OF CALIFORNIA

13 IRAJ KHOSROABADI, an Individual )

PLAINTIFFS FIRST AMENDED COMPLAINT

PLAINTIFFS FIRST AMENDED COMPLAINT

11 #3, Los Angeles, CA 90035, that provides aid to Americans (mostly of

PLAINTIFFS FIRST AMENDED COMPLAINT

1 in the County of Los Angeles.

11 Angeles, CA 90035. Exhibit E. Suite #1 used to be occupied by Mazgani

13 10. Neyaz Mazgani is a natural person residing in the County of Los

PLAINTIFFS FIRST AMENDED COMPLAINT

11 Representative) in California and qualifies to receive direct payments as a

13 16. Defendants have engaged in systematic and ongoing victimization of

PLAINTIFFS FIRST AMENDED COMPLAINT

PLAINTIFFS FIRST AMENDED COMPLAINT

11 print advertisements under Attorney Services even though Mahvash is not a

13 MSSI employs a licensed attorney on staff. Exhibit A. In at least one online

PLAINTIFFS FIRST AMENDED COMPLAINT

11 a seasoned attorney licensed to practice law in the State of California, (SBN:

13 secondary school) in academia and is currently working on a doctorate in law.

PLAINTIFFS FIRST AMENDED COMPLAINT

1 Robertson Blvd., and the entire Mazgani Family works there.

11 have to do to apply for disability benefits. While at a restaurant, a friend

PLAINTIFFS FIRST AMENDED COMPLAINT

PLAINTIFFS FIRST AMENDED COMPLAINT

13 (bold and italics added). Id.

PLAINTIFFS FIRST AMENDED COMPLAINT

11 Mazgani and Shohreh Sharifzadeh. Mahvash conducted the meeting in her

PLAINTIFFS FIRST AMENDED COMPLAINT

PLAINTIFFS FIRST AMENDED COMPLAINT

1 pay to lines blank to Mahvash Mazgani.

11 had the pay to lines and the date lines blank.

PLAINTIFFS FIRST AMENDED COMPLAINT

1 asked the postal worker if he would be willing to sign a statement describing

PLAINTIFFS FIRST AMENDED COMPLAINT

PLAINTIFFS FIRST AMENDED COMPLAINT

11 said fees. See Exhibits E, G,&S.

PLAINTIFFS FIRST AMENDED COMPLAINT

1 beneficiary receives an award of SSA benefits. Mahvash then sends in her

11 C. Defendants Collected Illegal Fees

PLAINTIFFS FIRST AMENDED COMPLAINT

11 payment of any fee that we have authorized.

PLAINTIFFS FIRST AMENDED COMPLAINT

11 appears that the representative is attempting to circumvent our fee

13 expenses or if the alleged out-of-pocket expenses appear unreasonable. GN

PLAINTIFFS FIRST AMENDED COMPLAINT

1 78. Blacks Law Dictionary defines Administrative Expenses as

13 D. Mahvash and Neyaz Laundered Money

PLAINTIFFS FIRST AMENDED COMPLAINT

PLAINTIFFS FIRST AMENDED COMPLAINT

13 $500. She also makes a $500 payment on an American Express card.

PLAINTIFFS FIRST AMENDED COMPLAINT

11 activity is an indication of money laundering.

PLAINTIFFS FIRST AMENDED COMPLAINT

13 deposit; and no credit card payments.

PLAINTIFFS FIRST AMENDED COMPLAINT

11 M. Mazgani and not Neyaz, yet it was deposited in Neyazs account.

PLAINTIFFS FIRST AMENDED COMPLAINT

11 emotional distress as a result of Defendants threats, aggressiveness and/or

PLAINTIFFS FIRST AMENDED COMPLAINT

11 404.1720 and 404.1705; (e) Whether Defendants breached a fiduciary duty;

13 Disabled Persons; (g) Whether Defendants violated Californias Consumers